Ceres 21st Century Utility July2010

The 21st Century
Electric Utility
Positioning for
a Low-Carbon Future
July 2010
A Ceres Report
Authored by
Ceres commissioned this report from Navigant Consulting.
Ceres is a national coalition of investors, environmental groups and other public interest
organizations working with companies to address sustainability challenges such as global
climate change. Ceres directs the Investor Network on Climate Risk, a group of more than
90 institutional investors and financial firms from the U.S. and Europe managing
approximately $10 trillion in assets.
Report Authors:
Forrest Small
Navigant Consulting
Lisa Frantzis
Navigant Consulting
Media Contact:
Peyton Fleming
Ceres
617-247-0700, ext. 120
fleming@ceres.org
Laverne Gosling
Navigant Consulting
202-481-7336
laverne.gosling@navigantconsulting.com
This report was made possible through support from the Bank of America Foundation and
the Surdna Foundation. The opinions expressed in this report are those of the authors and do
not necessarily reflect the views of the sponsors.
Ceres wishes to thank the many people who contributed to this report. Special thanks to
Rich Sedano of the Regulatory Assistance Project and Tim Woolf of the Massachusetts Dept.
of Public Utilities. Thanks also to the members of the Ceres team who provided valuable
insight and editing suggestions: Dan Mullen, Dan Bakal, Peyton Fleming, Meg Wilcox,
Andrea Moffat, Veena Ramani, and Meg Crawford.
Cave Dog Studio designed the final report.
Copyright 2010 by Ceres

Ceres
99 Chauncy Street
Boston, MA 02111
www.ceres.org
The 21st Century

Electric Utility
Positioning for
a Low-Carbon Future
July 2010
A Ceres Report
Authored by
The 21st Century Electric Utility
Preface by Mindy S. Lubber

Most experts who follow the U.S. electric power sector agree that the industry stands at a
crossroads. This Ceres report reaffirms that perspective; as report author Navigant Consulting
concludes, changes underway in the 21st century electric power sector create a level and
complexity of risks that is perhaps unprecedented in the industrys history.
Once extremely stable and predictable, todays electric power sector faces an array of
challenges and opportunities amid a fast-shifting landscape. New approaches to serving
customers by using less energy, cleaner energy and emerging technologies are taking hold at
the same time that business-as-usual approaches have become more expensive, complicated
and risky. Complying with scientists urgent calls to dramatically reduce greenhouse gas
(GHG) emissions also has enormous implications for the power sector, the largest source
of U.S. and global emissions. Responding to these trends requires nothing short of a
fundamental rethinking of how we produce, transmit and use electricity.
Investors are paying close attention to how electric utilities are responding to this shifting
landscape. The Investor Network on Climate Risk (INCR), a Ceres-organized group of more
than 90 institutional investors managing about $10 trillion in assets, has engaged with electric
utilities since 2003 on their strategies to mitigate climate risks and prepare for emerging
carbon-reducing regulations. A recent INCR report found that asset managers view the utility
sector as being uniquely exposed to climate risks. Earlier this year, after numerous requests
from investors, the U.S. Securities and Exchange Commission issued formal guidance
requiring utilities and other publicly-traded companies to disclose "material" climate-related
risks in their financial filings, including impacts from carbon-reducing policies.
But investors and analysts are increasingly aware that the discussion about the 21st century
electric utility extends far beyond carbon. Energy efficiency serving customers by helping
to reduce electricity demand is likely utilities most important energy resource in the 21st
century, as this report points out; but utilizing this resource requires a new business model
that doesnt rely on electricity sales to drive profits. And given the investment required to
modernize and decarbonize our electricity system an amount estimated well into the trillions
utility best practices such as transparent planning and proactive stakeholder engagement
are now essential business activities for mitigating political risks and facilitating cost recovery
of proposed investments.
This report identifies five key elements of a 21st century electric utility business model and
makes specific recommendations to utilities as they transition to a low-carbon future. It is
by no means the final word on this complex and constantly evolving subject. Rather it is
a starting point for utilities, policymakers, regulators, investors, analysts, and advocates
to consider the utility decisions and behaviors best suited to helping us realize the energy
future we all want a future that, as the report says, minimizes cost, risk and environmental
impact, and maximizes opportunity, options and societal benefit.
Mindy S. Lubber is president of Ceres and director of the Investor Network on Climate Risk.
Foreword by Tom King

Todays electric utilities face unprecedented challenges. On top of our traditional goals of
safety, efficiency and reliability, the modern utility must address global environmental issues
such as climate change, national security issues surrounding our dependence on foreign
energy, and a growing desire by customers to have greater control over their energy use
decisions to lower costs and decrease their environmental footprint.
Meeting our customers demands to turn these challenges into opportunities requires
transformation of the traditional electric utility business model. Delivering safe and reliable
electricity will always form the bedrock of what we do, but the modern utility must expand
its vision and adapt to changing circumstances in order for our employees to provide energy
sustainably for our customers, communities and shareholders.
This begins with addressing climate change, the seminal issue that impacts our global
environment and economy today. As public utilities, we should make our business decisions
and set our financial targets with climate change issues and carbon reduction goals at
the forefront. This ranges from factoring the price of carbon into major capital investment
decisions to elevating key sustainability issues such as climate change to the governance
level. At National Grid, one way we are trying to embody that approach is by linking executive
compensation to performance on specific goals in meeting greenhouse gas reduction targets.
Fortunately, as Ceres details in this 21st Century Electric Utility report, many of the actions
that we must take to address climate change will benefit our customers and communities in
a variety of ways. Energy efficiency is a prime example. Energy efficiency can cost as little as
3 cents per kilowatt hour saved, while electricity costs 6 to 12 cents per kilowatt hour. Thus,
energy efficiency measures reduce emissions, avoid unnecessary energy supply investments,
lower customer bills and create jobs for electricians, plumbers, laborers, and engineers.
Despite these obvious advantages, we have historically grossly underinvested in energy
efficiency as an industry. Altering this course by investing in all cost-effective energy efficiency
measures is the most effective way to both reduce greenhouse gas emissions and lower
customer bills.
Expanding and diversifying our investments in wind, solar and other forms of renewable and
low-emission electricity is also critical. This includes not only large scale renewable energy
projects, but facilitating local, distributed energy solutions from solar homes to fuel cells.
In conjunction with Smart Grid technologies that optimize energy delivery and use, these
alternative, innovative uses of energy will enhance our energy security by reducing our
dependence on foreign energy, make our electricity supply more diverse and reliable and
create sustainable green jobs.
To be sure, electric utilities cannot achieve these goals on their own it requires the support
of our customers and other stakeholders and supportive policies such as federal climate
change legislation, revenue decoupling and renewable energy and energy efficiency portfolio
standards. However, it is incumbent on us to lead the transformation of our industry, and
Ceres 21st Century Electric Utility report provides an indispensable blueprint for making the
transition a success.
Tom King is president of National Grid U.S.
iii
Executive Summary
The successful 21st century electric utility company will be very different from the utility
of the 20th century. To remain competitive, todays utility must respond to the risks and
opportunities from climate change, carbon costs, volatile fuel prices, emerging clean
technologies, expanding energy efficiency programs, increasing customer expectations and
competing third party energy providers. Responding to these challenges will require new core
competencies and revised business models for U.S. utilities.
The Shifting Landscape of the 21st Century Electric Power Sector

The business landscape for electric utilities is shifting quickly. In turn, the traditional operating
paradigm of building large generation facilities to sell ever-increasing amounts of electricity is
changing. Key drivers include:
The imperative to reduce greenhouse gas (GHG) emissions upwards of 80 percent
by 2050 (Figure ES-1);
Significant climate/clean energy policy momentum in a majority of U.S. states, with likely
near-term federal action that will further increase costs and complicate development of
fossil-fuel based electricity generation;
Continued declines in production costs for renewable energy technologies;
Growing support and uptake of regulatory policies to allow utilities to utilize large-scale
energy efficiency as the lowest-cost energy resource;
Implementation of Smart Grid technologies that offer utilities and their customers the
information and tools to better manage electricity usage;
Growing interest and activity in the development of plug-in electric vehicles (PEVs); and
Increasing recognition of domestic natural gas as a resource that is less carbon intensive
than other fossil fuels for large scale electricity generation, complementary to renewable
energy resources, and domestically abundant.
iv
Assumed Economy-wide CO2 Reduction Target

7
Historical
Emissions
Billion tons CO2
While each of these drivers will

materially influence the electric
power sector in the coming years,
one of the greatest effects will be
felt from climate change concerns
and the pursuit of steep reductions
in greenhouse gas emissions.
This is because the electric
power sector is the largest single
source of U.S. and global carbon
dioxide emissions, responsible for
approximately 40 percent of total
emissions. When carbon dioxide
emissions are factored in, the
economics of producing electricity
with large, centralized fossil-fueled
generation will change considerably.
2005 = 5,982 mmT CO2

2012 = 3% below 2005
(5,803 mmT CO2)
2020 = 17% below 2005

(4,965 mmT CO2)
Remainder
of U.S.
Economy
2030 = 42% below 2005

(3,470 mmT CO2)
2050 = 83%
below 2005
(1,017 mmT CO2)
2
1
83% Reduction in CO2

emissions from 2005
U.S. Electric
Sector
0
1990
2000
2010
2020
2030
2040
2050
Figure ES-1: Illustration of 80 percent CO2 reduction by 2050

Source: Electric Power Research Institute
Executive Summary
Clean energy resources available today will play a critical role in achieving CO2 reduction
targets. Energy efficiency and some renewable energy resources can reduce GHG
emissions cost-effectively, while maintaining electric system reliability and reducing
system-wide risk. However, deploying these clean energy resources at a large scale
presents fundamental challenges:
F
irst, most utilities lack sufficient regulatory support;
S
econd, the traditional utility business model is based on electricity sales which would be
eroded by energy efficiency and distributed clean energy resources; and
T
hird, the capabilities of the existing electricity delivery infrastructure may limit the
amount of clean energy resources that can be integrated without compromising reliability
or increasing cost excessively.
A utility that deals effectively with these trends, and receives sufficient support from regulators
and legislators, will be better positioned to succeed in the 21st century. All else equal, such
a utility is also more likely to attract lower cost capital, enabling it to earn stronger returns for
investors. On the other hand, a utility that fails to effectively manage risk, including higher
carbon exposure, may suffer greater financial impacts if climate legislation takes hold and
fossil generation costs rise.
Factor
20th Century
21st Century
Business Model
Simple, based on steadily increasing

electricity sales typically from an
expanding asset base of centralized
generation and traditional1 delivery
infrastructure
Complex, integrated energy

services serving diverse and
evolving customer needs with an
information-enabled infrastructure
Electricity Demand
Increasing
Flattening with potential decline,

exception being the deployment of
new electric vehicles2
Capacity Cost
Average cost of new capacity stable

or declining
Average cost of new capacity

increasing3
Cost of Carbon
None
Moderate and increasing
Utility Objectives
Reliability, Customer Service,

Affordability (low rates), Returns to
Shareholders4
Reliability, Environmental Quality,

Service Quality, Affordability (low
bills), Returns to Shareholders
Role of the Customer
Passive
More active, equipped with the

technology and incentives to
manage energy consumption and
generate energy
Table ES-1: Differences between the Utility Business in the 20th and 21st Centuries
1. Although new technologies have been introduced, long equipment lifecycles, standardization and utilities aversion
to risk have tended to limit the implementation of innovative transmission and distribution system technology.
2. New energy services such as powering electric vehicles may increase demand, but the net impact is
currently unclear.
3. The cost of new capacity will be partially offset as low carbon generating resources become commercially mature.
4. Investor owned utilities, in addition to managing costs, have the goal of earning market-based returns for
shareholders, while publicly owned utilities have the goal of minimizing cost for members.
Executive Summary
Key Elements of a 21st Century Utility Business Model
In addition to maintaining highly efficient business operations and effectively managing capital,
successful U.S. utilities in the 21st century will need to do several things well:
1. Manage carbon across the enterprise. With national climate and energy legislation under
consideration and a patchwork of state and regional carbon-reducing policies already in place,
it is expected that all utilities will have to deal with expected carbon controls in the future, and
probably within their system planning horizons. Utilities should account for carbon emission costs
in resource planning, and align those costs and risks with likely carbon-reduction scenarios.
Failing to effectively mitigate carbon risk will lead to higher shareholder and lender risks, as well
as unreasonably burdening ratepayers with higher costs. Investors and utility commissions will
be scrutinizing electricity supply portfolios more closely to evaluate impacts associated with new
climate regulations.
/kWh (2010$)
2. Pursue all cost-effective energy efficiency. Energy efficiency is among the least expensive
energy resources for utilities (Figure ES-2), and one of the most cost-effective ways to reduce
GHG emissions. As policymakers, regulators and utilities grapple with the challenge of achieving
steep emissions cuts, energy
efficiency is likely to emerge as
Levelized Cost of Electricity
18.0
the single most important energy
Notes:
Assumes Federal & state incentives.
16.0
resource for the 21st century power
CSP assumes trough technology.
16.5
Natural gas price of $4.57/MMBTU
14.0
sector. Studies show that energy
13.5
12.0
efficiency lowers consumer energy
10.0
bills, and implementing it becomes
9.5
9.5
8.0
less expensive as utilities use it more
7.5
6.0
widely. Because energy efficiency
6.0
6.0
4.0
reduces electricity sales, it has
4.5 3.5
2.0
not been fully adopted by most
2.5
3.0 2.0
0
utilities due to their rate structure
r
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w
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lea
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However, supportive regulations
m
r
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Co
and ratemaking mechanisms
are making it more attractive for
Figure ES-2: Cost of EE as Compared to Other Resources
utilities to pursue cost-effective
Source: Navigant Consulting, Inc.
energy efficiency.
3. Integrate cost-effective renewable energy resources into the generation mix. The U.S. is
one of the strongest and most attractive renewable energy markets in the world. With continued
downward movement in production costs and prices, and upward pressures sustaining
or increasing fossil-generated power costs, simple operating economics are becoming an
increasingly powerful driver for renewables growth. The U.S. has seen substantial and promising
growth in large-scale wind and concentrating solar power (CSP) installations in recent years.
However, achieving Renewable Portfolio Standard (RPS) targets using only large-scale renewable
energy resources will be challenging due to the need for new transmission development which
emcompasses siting, permitting, environmental and cost constraints. For these reasons, a
growing number of states and utilities are pursuing expanded investment in distributed energy
vi
Executive Summary
resources (DER) such as solar photovoltaics (PV) (Figure ES-3). Recent analysis by Navigant
Consulting indicates that in some parts of the U.S. PV has the potential to achieve grid parity by
2015, or sooner depending on pricing and incentive levels.
4. Incorporate Smart Grid technologies for consumer and environmental benefit. Smart
Grid technologies, including smart metering, distribution automation and synchrophasor
monitoring are entering the mainstream, with most U.S. utilities involved in full-scale system
implementations or pilot programs.
An effective Smart Grid will help
RPS Policies
Solar carve-outs/compliance
reduce both peak electricity demand
Revenue
Opportunity to rate-base solar assets and leverage
and overall energy consumption. It
existing corporate functions
Opportunity
will integrate increasing amounts of
Federal ITC
Utilities can now use the 30% ITC through 2016
renewable energy and improve grid
Quick way to deploy RE, avoiding challenges
efficiency. It will also help utilities gain
Added Resource
related to transmission, interconnection, permitting
operational efficiencies and manage
3rd party solar service providers could lead
infrastructure and operating costs.
3rd Party Threat
to utility revenue erosion
Utilities should ensure that they
Brand Halo
Some utilities see solar as a way to create a brand halo
implement the Smart Grid in a manner
that maximizes consumer and clean
Potential FASB
Financial Accounting Standards Board may reclassify
energy benefits, including energy
Power Purchase Agreements (PPAs) as debt
Changes
efficiency and demand management,
Figure ES-3: Key Drivers of Utility Ownership of PV
and integration of renewable and
distributed energy.
5. Conduct robust and transparent resource planning. Utilities should employ open and
transparent planning processes that consider the risks, probabilities, benefits, impacts and
applications of multiple energy resources under various scenarios. Planning processes should
include a full commitment by utilities to implement cost-effective energy efficiency and
renewable energy. Resource planning should involve greater stakeholder involvement on a
wider regional level and consider the full spectrum of energy efficiency and distributed energy
resources. Clear policy frameworks allow all parties to better understand the goals and regulatory
objectives that will influence or constrain the planning process. Finally, utilities should update
planning processes to reflect current and future costs for CO2, energy efficiency, distributed
energy resources, equipment and permitting.
Financial Implications
Building a clean energy supply and a Smart Grid infrastructure will require utilities to capitalize
hundreds of billions of dollars in rate base. Given that average retail electricity rates have
increased an average of 50 percent across all sectors over the past 10 years,5 increasing them
even more will be challenging. It is expected that regulators will be more comfortable approving
large-scale investments and their associated rate adjustments when the associated risks have
been clearly accounted for and managed. Protracted approval processes associated with
investments that are perceived by regulators to be unclear or questionable present a significant
financial risk to utilities. Some financial analysts are predicting that key credit metrics for utilities
5. U.S. Energy Information Administration
vii
Executive Summary
will be negatively impacted in the long term due to cost recovery risks from downward
rate pressure.
Key Regulatory Policies for the 21st Century Electric Power Sector
Mandatory regulatory policies will be needed to enable utilities to deploy the approaches and
technologies described in this report. These policies, which typically fall within the purview of
state governments and utility regulatory commissions, include:
Clean energy policies that set an overall direction aligning clean energy goals across
government agencies (including utility regulators); promote the development and
compatibility of complementary policies; and demonstrate a commitment to clean
energy resources;
Enforceable Renewable Portfolio Standards that incentivize compliance, provide clear
market signals for utilities, and reward those parties that deliver results;
Revenue decoupling to remove utilities inherent disincentive to implement large-scale
energy efficiency;
Effective net metering for distributed generation to facilitate consumer investment
in on-site renewable energy generation; and
Incentive ratemaking for utilities to provide premium returns on the right
utility investments.
Additionally, it is likely that the federal government will set policies that put a price on carbon and
increase energy independence, renewable energy and energy efficiency.
Conclusion
Utilities, whether investor owned or consumer owned, are public entities that build and operate
the electricity infrastructure that powers our nation and economy. They have an obligation to
serve customers in a way that minimizes financial and environmental risk. The ideas discussed
in this paper are based on two lynchpin principles that utilities should:
Minimize cost, risk, and environmental impact; and
Maximize opportunity, options, and societal benefit.
Utilities need to deploy capital in ways that provide affordable and secure electricity, while
meeting the nations climate objectives. Pursuing approaches that are overly capital-intensive
puts upward pressure on electricity rates and increases the risk of unfavorable recovery of cost.
This, in turn, could lower a utility's credit rating and increase its cost of capital. Utilities that
pursue diversified strategies utilizing cost-effective energy efficiency and distributed energy
resources are likely to reduce capital investment risk.
The most successful utilities will likely be those that pursue this agenda aggressively,
transparently, and across all aspects of the business. The inherent risk management benefits of
this approach are apt to be recognized by the financial institutions that rate and lend to electric
utilities. The ongoing support of credit rating agencies and financial institutions is crucial to
maintaining the momentum of capital into the ongoing transformation from a simple, regimented,
centralized commodity seller to a complex, diversified, innovative service provider.
viii
Key Report Recommendations for U.S. Utilities

Manage Carbon Across the Enterprise
Make an overall corporate commitment to minimizing carbon emissions as a central
guiding policy;
Perform rigorous scenario analysis that assumes a range of carbon costs;
Incorporate carbon prices into business and energy resource plans;
Complete an internal inventory of greenhouse gas (GHG) emissions using widely accepted
standards;
Set a meaningful GHG reduction target that will help prepare the company for future
regulation; and
Disclose relevant data and plans thoroughly to stakeholders.
Pursue All Cost-Effective Energy Efficiency

Recognize the value of energy efficiency;
Actively seek out lessons learned and best practices from other jurisdictions;
Advocate for appropriate policies that support aggressive energy efficiency;
Develop goals that aim for at least 1% annual electricity savings, consistent with results
achieved by leading utility programs;
Fully include energy efficiency in electric system resource planning; and
Follow rigorous and transparent monitoring and verification (M&V) protocols.
Integrate Cost-Effective Renewable Energy

Actively pursue development of a range of renewable energy projects to meet and/or
exceed state renewable targets;
Consider owning PV assets to gain experience in their implementation given the potential
near-term grid parity and possible threat of third party providers serving utility customers
solar power;
Evaluate business models being used by private competitors and other utility companies
to own distributed energy resources and other renewable assets; and
Create new risk hedging and grid management mechanisms to deal with variance in
customer load response and intermittent renewable energy resources.
Incorporate Smart Grid Technologies for Consumer and

Environmental Benefit
Simplify the interconnection and integration of distributed renewable energy resources;
Leverage the operational efficiencies provided by Smart Grid technology to reduce
operational costs;
Prioritize Smart Grid investments that seek to maximize benefits from energy efficiency,
energy delivery, and clean energy technologies;
ix
Key Report Recommendations for U.S. Utilities

Provide customers with information and energy management technologies that are
aligned with effective pricing programs; and
Build out the Smart Grid by pursuing a long-term capital improvement program premised
on delivering enhanced value to consumers.
Conduct Robust and Transparent Resource Planning

Utilize transparent analysis and decision frameworks;
Fairly evaluate energy efficiency and renewable energy in robust scenario analyses;
Facilitate input from key stakeholders; and
Educate the public and policy makers about complex energy issues
Table of Contents
Preface . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . i
Foreword . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iii
Executive Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iv
Key Report Recommendations for U.S. Utilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ix
I. Introduction: The Shifting Landscape of the 21st Century Power Sector . . . . . . . . . . . . . . . 1
Climate Change: A Major Challenge . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
Energy Security: A Growing National Priority . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
Customer Involvement: Leveraging Technology to Better Manage Energy Use . . . . . . . . . . 2
Grid Technology: Creating Greater Intelligence . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
Electricity Demand: Multiple Factors Pushing it Down . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
Renewable Energy: Gaining Share in the Supply Mix . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
Natural Gas: An Increasingly Important Strategic Resource . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
Coal: Facing an Array of Challenges . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
Nuclear Power and Carbon Capture and Storage: Significant Uncertainties Remain . . . . 3
II. Five Key Elements of a 21st Century Utility Business Model . . . . . . . . . . . . . . . . . . . . . . . . . 5
1. Manage Carbon Across the Enterprise . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
2. Pursue All Cost-Effective Energy Efficiency . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
3. Integrate Cost-Effective Renewable Energy Resources into the Generation Mix . . . . . . 16
4. Incorporate Smart Grid Technologies for Consumer and Environmental Benefit . . . . . 21
5. Conduct Robust and Transparent Resource Planning . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23
III. Financial Implications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25
IV. Key State Regulatory Policies for the 21st Century Power Sector . . . . . . . . . . . . . . . . . . . 30
Clean Energy Policies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30
Enforceable Renewable Portfolio Standards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31
Revenue Decoupling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32
Effective Net Metering for Distributed Generation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33
Incentive Ratemaking for Utilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34
I. Introduction:
The Shifting Landscape of the 21st Century Power Sector
Powerful trends are transforming the U.S. utility sector, including climate change, energy
security, and energy price volatility concerns; increasing deployment of alternative resources
like energy efficiency and renewable energy; and shifts in natural gas and other fossil fuel
industries. Utilities that respond most effectively to these key trends and whose regulators
and legislators support them in doing so will be best positioned to succeed in the 21st
century. Below are highlights of key drivers facing the industry.
Climate Change: A Major Challenge

Climate change is one of the biggest and most complex challenges the world faces today
and utilities are commonly identified as key players in how to respond.
The most recent assessment from the Intergovernmental Panel on Climate Change (IPCC), a
worldwide body of hundreds of climate scientists from more than 130 countries, concludes
that warming is unequivocal and that observed increases in temperatures are very likely
due to rising greenhouse gas concentrations from human activity. While there is uncertainty
on how much warming we can expect, there is strong scientific consensus of the urgency for
reducing heat-trapping emissions 50 to 80 percent by 2050.
The electric power sector produces 40 percent of U.S. carbon dioxide (CO2) emissions,
making it a top target of carbon-reducing policies. State and regional governments are
already limiting greenhouse gas emissions from electric generation plants. Sector companies
operating in multiple states face management challenges and associated costs from
these varying regulatory environments. Eighteen states have taken initial steps towards
greenhouse gas (GHG) trading systems, including the Western Climate Initiative, Californias
Global Warming Solutions Act, Floridas State Action Team on Energy and Climate, and the
Regional Greenhouse Gas Initiative in the northeast. Some states have taken action to limit
CO2 emissions from electric generation by prohibiting utilities from building new coal-fired
generation without carbon sequestration, or from signing long-term supply contracts from
such generation. Some state laws also require new generation plants to offset some other their
projected CO2 emissions.
In the U.S., national climate legislation to reduce CO2 emissions from utilities and other
sources is widely seen as inevitable, although such legislation may not pass in 2010. In
June 2009, the House of Representatives passed the American Clean Energy and Security
Act, landmark legislation to cap GHG emissions across all sectors of the economy. As this
report went to press, several alternative bills to limit carbon emissions across the economy or
specifically in the electric power sector were under consideration in the Senate.
Energy Security: A Growing National Priority

In this country there is strong interest in achieving greater energy independence and
increasing the security of our energy infrastructure. This is leading to growing support for the
transition of Americas transportation fleet away from oil toward other energy sources, including
electricity. The vigorous development of plug-in electric vehicles (PEVs) would require
increased flexibility and robustness of the electricity infrastructure. Enhancing the reliability
and resilience of the electricity grid to withstand major equipment outages, weather effects,
and potential terrorist attacks is also gaining attention.
I. Introduction:
Customer Involvement: Leveraging Technology
to Better Manage Energy Use
The energy industry, like most others, will continue to experience an evolution in customer
expectations, from information on demand to high degrees of control and engagement to
the ability to create collaborative and personalized interaction channels with energy service
providers. Experts increasingly mention customer involvement and the conversion of enduse load into an energy resource as one of the most transformative changes the industry
will undergo. The capability and complexity of loads, including smart appliances, energy
management systems, plug-in electric vehicles, and distributed energy resources, are
creating the opportunity to engage customers as active energy partners rather than passive
ratepayers. The expectation is that new energy products
will emerge, including service bundles, customized service
Defining the U.S. Electric
levels, and retail energy exchanges.
Utility Industry
Grid Technology: Creating Greater Intelligence

Over the 20th century, many of the core technologies used
in the power sector for the production and delivery of
electricity remained relatively unchanged. Even now,
much of the power equipment in service would be
recognizable to the utility engineers from the early 1900s.
However, over time utilities have applied technology
strategically to increase reliability and reduce cost. In
recent years, advancements in information technology,
communications and electronics have been applied
to electric power systems. Increases in capability and
reductions in cost for this technology mean that utilities
are deploying it at greater scale, which will enable
fundamental changes in the way the grid is configured
and operated.
Electricity Demand: Multiple Factors

Pushing it Down
In the late 1990s and early 2000s, energy use per capital
in the U.S. leveled off and began to decline slightly.5
The recent economic recession resulted in a sharp
reduction in energy use, and it is not clear how quickly
demand will return to pre-recession levels. The increasing
attention and activity around energy efficiency means
that electricity demand could continue to drop over the
long term.
5. U.S. Energy Information Administration, Annual Energy Outlook 2010
In recent years, the idea of an electric utility

has become more diverse and complex. Policy
changes at the federal and state levels have
reshaped the electric power sector and the
structure of the organizations that generate, deliver
and sell electricity to end users. For the purposes
of this report, utilities include organizations that
deliver electricity to customers and charge those
customers for that service. These utilities may
obtain electricity from their own generators, from
other parties, or both, but it is not necessary that
they own and operate generation.
Different types of utilities are regulated differently.
Investor owned utilities are for-profit companies
regulated by state utility commissions. Municipal
utilities are regulated by municipal governments in
their various forms. Cooperatives are regulated by
boards or committees elected by their members,
subject to Rural Utility Service standards. (Co-ops
may also be regulated by state commissions in
certain aspects of their operations.) The structure
and regulation of different utilities affect the
business models and incentives that, in turn, affect
the way each utility approaches clean energy. This
report focuses primarily on investor owned utilities,
although much of the content should be relevant
for municipal utilities and cooperatives.
I. Introduction:
Renewable Energy: Gaining Share in the Supply Mix
Renewable energy is benefiting from advancements on multiple fronts. State policies are
mandating it, technology advancements are increasing its performance, and manufacturing
scale and process improvements are driving down cost. While renewable energy is still a
relatively small portion of the overall energy resource mix, it has been a significant part of new
capacity additions in the U.S. in the last few years. This trend is expected to continue.
Natural Gas: An Increasingly Important Strategic Resource

Energy security concerns and technology development are driving momentum for increased
reliance on domestic natural gas reserves. Recent technological breakthroughs in extracting
natural gas from shale and other tight formations have led to a startling reassessment of the
nations natural gas supplies, previously thought to be dwindling. Some experts now predict
that the U.S. has over 100 years of proven and potential natural gas supply at current levels
of demand. Natural gas is positioned to play a growing role as a complement to variable
renewable energy resources. In addition, natural gas can help optimize overall energy
efficiency by integrating thermal and electric technologies and end-uses.
Coal: Facing an Array of Challenges

The majority of the nations coal-fired power plants are at least 30 years old, with many
approaching retirement age. Forthcoming regulations from the U.S. Environmental Protection
Agency (EPA) to reduce power plant emissions of nitrogen oxides, sulfur dioxide, mercury
and other air toxics are expected to materially increase and accelerate coal plant retirements;
Bernstein Research concludes that such EPA regulations would likely result in the retirement
of roughly a quarter of U.S. coal-fired generation by 2015.6 In 2008, the U.S. Geological
Surveys investigation of the nations largest and most profitable coalfield found that its
economically recoverable coal reserves could amount to only 6 percent of previous estimates,
raising questions about the long-term price and availability of coal in other areas of the U.S.7
More than 120 proposals for new coal-fired power plants have been canceled over the last
decade due to concerns about environmental and financial risks, while another 50 face
continued legal opposition.8
Nuclear Power and Carbon Capture and Storage:

Significant Uncertainties Remain
Carbon capture and storage (CCS) and nuclear power are important technological options to
decrease carbon emissions, but face considerable financing and implementation challenges.
In a February 2010 report, Moodys concluded that companies that pursue new nuclear
generation will take on a significantly higher business and operating risk profile, based on
the risks associated with long-term approval, construction and execution processes needed
6. Bernstein Research, U.S. Utilities: A Visit to Washington Finds Utility Lobbyists & Environmentalists Agreeing on
the Grim Outlook for Coal, 9 March 2010.
7. U.S. Geological Survey, Assessment of Coal Geology, Resources, and Reserves in the Gillette Coalfield, Powder
River Basin, Wyoming, December 2008.
8. Lester Brown, Coal-Fired Power on the Way Out?, 24 Feb 2010. http://ipsnews.net/news.asp?idnews=50449.
I. Introduction:
for such projects. While it is likely that some new nuclear plants will begin construction
and a small number of CCS pilots will be undertaken in the near term, it will be at least a
decade before utilities will be able to confidently pursue development of these resources
on a large scale.
Individually, each of these trends creates a degree of uncertainty for electric utilities and the
power sector. Combined, they signal a major shift in the landscape of the 21st century power
sector. The following report discusses what electric utilities can do to be successful in this
new environment.
II. Five Key Elements of

a 21st Century Utility Business Model
1 Manage Carbon Across the Enterprise
The discussion surrounding climate change legislation has matured to the point where
federal action designed to limit greenhouse gas (GHG) emissions is likely in the near term.
Numerous state and regional policies have already emerged. Most utilities are now thinking
about climate change, and commitments to clean energy and environmental stewardship are
increasingly common. In addition to reliable, affordable electricity, many utilities have added
clean to their long-term strategic objectives.
National Grids Approach to

Carbon Management
National Grid presents a good example of how a
utility can integrate carbon costs into its business
operations. In 2008, National Grid set a long-term
target to reduce its Scope 1 and Scope 2 GHG
emissions by 80 percent by 2050. The company
also discloses a shorter-term reduction target of
45 percent by 2020. The timeframes and
magnitude of these goals are closely aligned with
reduction goals from the scientific community.
Truly managing the financial risk associated with carbon will

require more than acknowledgement that it is important.
Utilities should account for carbon emission costs in their
resource planning and properly and fully recognize the
costs and risks associated with likely scenarios for carbon
reduction.9 Further, the likelihood that coal-fired power
generation will become a more expensive and less integral
part of baseload generation in the coming years should be
a key consideration as utilities map next steps.
While some utilities are beginning to account for carbon

risk in their planning, other utility executives and analysts
believe that the uncertainty around pending legislation is
The utility companys executives have been using
so great that the value of planning and analysis is quite
a shadow price for carbon of $50 per ton in its
limited. Uncertainties aside, the lack of a robust and
business decisions and planning. Carbon budgets
consistent response by utilities to carbon-related financial
have been established by business lines, and
risks has raised concerns among some financial analysts;
incentive compensation for executives is linked to
as Moodys observed in a February 2010 report, The
achieving carbon reductions.
electric utility sector does not appear to be responding
to the potential climate risks with any sense of urgency,
and some companies may find themselves unprepared for legislative changes. We think
preparations to strengthen the balance sheet should have begun years ago, and worry that
the opportunity costs associated with inaction may yet prove substantial.10
The Legislative and Regulatory Context

A number of federal bills have been introduced that aim to reduce GHG emissions using
cap-and-trade or cap-and-dividend approaches (Figure 1). The most prominent of these
are the American Clean Energy and Security (ACES) Act of 2009 (H.R. 2454), which was
passed in the House in June 2009, and the American Power Act discussion draft, which
was introduced by Senators Kerry and Lieberman into the Senate in May 2010. Although the
details of the various bills differ, most have proposed similar reductions in GHG emissions,
which are significant (83 percent reduction by 2050).
9. Influence of Retail Market Structure on Financial Impacts of Multi-Pollutant Bills at the Company Level,
Kevin Cooney, James Henderson and Robert Repetto, Electric Utilities Environmental Conference, Tucson, AZ,
January 20, 2004.
10. Moodys Investors Service, U.S. Electric Utilities See Some Clarity in Evolving Federal Energy Policies,
February 2010.

Net Estimate of Emissions Reductions Under Pollution Reduction Proposals
Million metric tons CO2e
States and regional entities are

in the 111th U.S. Congress, 20052050 June 8, 2010
9000
already limiting greenhouse gas
Business as usual*
8000
emissions from electric power
2005 levels
plants, creating a patchwork national
7000
1990 levels
market in the absence of federal
6000
Short-term
projected
legislation. Multi-state utilities already
emissions*
5000
face management challenges and
4000
associated costs from these varying
3000 CLEARA S.2877 (as introduced)**
regulatory environments. Eighteen
Emission cap only
states have taken initial steps toward
2000 APA (discussion draft) (as introduced)***
ACESA H.R.2454 (as passed)***
Emission cap only
Emission cap only
GHG trading systems, including
Caps plus all complementary requirements
Caps plus all complementary requirements
1000
Potential range of additional reductions
Potential range of additional reductions
the Western Climate Initiative,
0
Californias Global Warming Solutions
2005 2010
2015
2020
2025
2030
2035
2040
2045 2050
For a full discussion of underlying methodology, assumptions and references, please see http://www.wri.org/usclimatetargets
Act, Floridas State Action Team
* Business as usual emission projections are from EPAs reference case for its analysis of the Waxman-Markey bill. Short-term
projected emissions represent EIAs most recent estimates of emissions for 20082010.
** The CLEARA sets economy-wide reduction targets beginning with a 20 percent reduction from 2005 levels by 2010. However,
on Energy and Climate, and the
additional action by congress would be required before these targets could be met. Reduction estimates do not include emissions
increases above the cap that could occur if the safety-valve is triggered.
Regional Greenhouse Gas Initiative
*** The APA and the ACESA allow offsets from emission reduction activities outside the cap to be used for a portion of compliance.
If these offsets are not real, additional, verifiable and permanent, net emissions reductions would decrease proportionately.
11
in the Northeast (Figure 2).
Figure 1: CO2e Emission Reductions Required by Waxman-Markey,
Several states, including California,
Kerry-Boxer, Cantwell-Collins, and Kerry-Lieberman
Montana, Oregon and Washington,
Source: World Resources Institute
have passed laws that prohibit
utilities from building or signing long-term contracts with new coal generation without carbon
sequestration, and that require new plants to offset some of their projected CO2 emissions.12
With national climate and energy
legislation in process and a
patchwork of state and regional
efforts advancing in the meantime,
it is inevitable that all utilities will
have to deal with such a system in
the future, and probably within their
timeframe of their planning horizons.
However, the details of climate
change proposals can take many
forms, and until such details are fully
in place, significant implementation
uncertainties will remain. A utility will
Western Climate
Initiative (WCI)
Midwestern GHG Reduction

Accord (MGGA)
Regional Greenhouse
Gas Initiative (RGGI)
MGGA Observers
RGGI Observers
WCI Observers
AB32 and WCI
State Action
Team on Energy
and Climate
Figure 2: State and Regional Programs Involving CO2 Emissions Trading

11. Uncovering the Full Renewable Energy Potential, renewable Energy World Conference & Expo, Navigant
Consulting Pre-Conference Workshop, March 2009.
12. C
alifornia Senate Bill 1368 prohibits the states utilities from taking new ownership interest in, or signing new
contracts of five years or longer for baseload generation with a CO2 emission rate exceeding that of a combinedcycle natural gas unit. Washington Senate Bill 6001 includes similar restrictions. Montana House Bill 25 prohibits
the state PUC from approving a utility application to lease/acquire an equity interest in a coal plan constructed
post-2006, unless it has at least 50 percent capture and storage of CO2, and requires use of cost-effective carbon
offsets if leasing/acquiring an equity interest in a power plant fueled by natural or synthetic gas and constructed
after 2006. Oregon HB 3283 requires that new baseload gas generation and new non-baseload generation
mitigate projected CO2 emissions in excess of a specified level. Washington HB 3141 is similar.

need to use rigorous risk management approaches to be best prepared for a range
of scenarios. Elements within the proposed national cap-and-trade systems are outlined
in Table 1.
Key Design Variables of Cap-and-Trade Systems That May Vary with Legislation
Emissions Cap
The level of the system cap

Timing of reduction of cap
Allowances
How allowances will be allocated, and who they will be allocated to

Which types of utilities will be held responsible to the trading system,
and how their requirements will differ
Amount of banking / borrowing allowed in trading system
Offsets
Criteria for determining legitimate sources of carbon offsets

Amount of offsets, both domestic and international, allowed in the system
Interaction with
Existing Systems
Links to other trading systems, such as the European Union

Greenhouse Gas Emission Trading System (EU ETS)
Interaction of a national cap-and-trade with existing state or
regional systems.
Table 1: Key Design Variables of Cap-and-Trade Systems (Varying with Legislation)

As the costs, complexity, and effectiveness of a market-based system are debated, the
Environmental Protection Agency (EPA) has also been proceeding with GHG regulation under
the Clean Air Act (CAA). This authority is based on a 2007 Supreme Court ruling allowing
EPA to use the Clean Air Act to regulate GHG emissions.13 Utilities may be exposed to GHG
regulatory risk stemming from the CAA.
Effective Carbon Management

While the details of eventual federal, state and regional clean energy regulations will influence
their impact, utilities will increasingly need to manage carbon emissions with a focus on
the financial liabilities associated with these emissions. For example, analysis by Standard
& Poors (S&P) suggests that companies with carbon intensive generation portfolios could
face negative earnings impacts of between 10 and 20 percent.14 Electric utilities should view
this imperative alongside other issues facing the industry such as grid integration of variable
generation, transmission constraints, uncertain demand growth and differing electricity
market structures all of which can influence generation and portfolio planning and resource
choices. Moreover, uncertain fuel (and carbon) prices, uncertain responses from regulators
who set rates, different cost trajectories for renewable energy technologies and localized
siting/permitting bottlenecks for new projects can further complicate strategic decisions on
precisely how to cost effectively lower carbon emissions.
Suboptimal decision-making processes on carbon mitigation can lead to higher risks for
shareholders and lenders as well as unreasonably burdening ratepayers with higher costs.
In a carbon-constrained economy, capital providers and utility commissions will increasingly
13. Massachusetts v. Environmental Protection Agency, 549 U.S. 497 (2007)
14. Standard and Poors, How Cap-And-Trade Will Affect U.S. Power Markets and Merchant Generators
Profitability, September, 2009.

examine generation and fuel
portfolios to evaluate risk associated
with potential new regulations. The
complexity of this new regulatory
situation is highlighted in Figure 3,
although by no means does this
graphic represent an exhaustive
list of financial issues arising from
carbon emissions.
Old Situation
Market Drivers
and Constraints
Regulatory
Requirements
New plant construction is
driven by load growth. Weak RPS
requirements and no carbon
costs marginalize the need to
diversify into clean energy.
The financial community is

increasingly aware of the risk
that carbon-emitting generation
represents in the energy portfolios of
utilities. However, it does not appear
that a consistent means for valuing
that risk has been developed.
While regulatory uncertainty
makes it challenging to definitively
assess carbon risk, analysts and
utilities should still be performing
extensive scenario analysis to help
guide decision-making. Existing
frameworks, such as the Carbon
Principles Enhanced Environmental
Due Diligence, could be useful for
supporting such analysis.
It is essential that utilities account for
the cost of carbon in their resource
planning. Even though the details
of legislation could significantly
influence the ultimate carbon price,
accounting for a range of potential
carbon costs will lead to more
prudent decision-making.
Generation Level
and Fuel Mix
of Portfolio
Portfolio mix is
predominantly driven by
available lowest fuel costs.
Financial impacts are

predominantly impacted
by local PUCs.
New Situation
How carbon costs are recovered, and the resultant
financial impact, can impact portfolio choices
Resources availability, grid integration and
transmission issues for renewables can have varying
financial impacts, influencing portfolio choices
Time lags between load growth
and renewable mandates could result
in over capacity, impacting finances
Market Drivers
and Constraints
Regulatory
Requirements
Generation Level
and Fuel Mix
of Portfolio
Financial Impacts
of Portfolio Choices
Portfolio choices are complicated by balance

sheet impacts of stringent RE mandates and
pending GHG disclosure requirements
Carbon costs could impair coal generation
assets impacting balance sheet or trigger
adjustment clauses in PPAs, impacting costs
Portfolio choices can be complicated by electricity
rate impacts associated with balancing lower
carbon compliance costs with the high
installation costs of renewables
Note: This diagram is indicative only and not an accurate representation of financial relationships
Figure 3: Graphical Representation of Current and Future Relationships

between Portfolio Drivers and Financial Impacts
The results of a Lawrence Berkeley

National Laboratory study15 of utility practices for quantifying carbon financial risks indicate
that the best-equipped utilities will have planning scenarios that include:
the most likely future regulatory outcomes;
a wide range of possible carbon prices;
15. M
anaging Carbon Regulatory Risk in Utility Resource Planning: Current Practices in the Western United States,
Galen Barbose, Ryan Wiser, Amol Phadke, and Charles Goldman, Ernest Orlando Lawrence Berkeley National
Laboratory, March 2009.
Financial Impacts
of Portfolio Choices

a diverse set of low-carbon portfolios capitalizing on energy efficiency
and renewable resources;
1020 year time horizons;
potential indirect effects of carbon regulation;
accounting for risks attributable to uncertainty in future technology costs; and
the value of emissions avoided through EE and reduced carbon regulatory risk.
Long-Term Planning with Carbon Scenarios

The resource planning process at PacifiCorp, an Oregon-based
utility, provides an example of robust planning that can curb
carbon risk. The process includes a range of carbon prices,
a long-term outlook, and potential indirect effects of carbon
regulations in support of portfolio development. The company
also accounted for EE in their candidate portfolios, incorporating
their base case carbon prices into their assessment of EE cost
effectiveness. The Oregon PUC required PacifiCorp to include
carbon costs in their planning and helped to shape how the utility
accounted for carbon in its planning process.
PacifiCorp identified a broad range of candidate portfolios, some
of which included planning horizons out to 2026. Many portfolios
included a resource mix that exceeded Oregons current
renewable portfolio standard (RPS) targets. Potential indirect
effects of carbon regulations included the impacts on electricity
market prices, natural gas prices, air pollutant permit prices,
and regional generation expansion. Product cost models were
developed to create electricity price forecasts for each scenario.
Finally, PacifiCorp used a capacity expansion model to determine
how resources performed across carbon scenarios, helping them
to more transparently and accurately incorporate carbon into
the portfolio selection process. A threshold analysis was used to
determine a carbon price point at which a candidate portfolio
would become the preferable least-cost option. This approach
allows the utility to consider the probability of carbon prices
reaching a point with major implications for the composition of
the least-cost portfolio.
Utilities should measure their carbon

footprint in detail to fully understand their
exposure. Existing reporting standards
such as EPAs GHG Reporting program,
the Global Framework for Climate Risk
Disclosure, the Carbon Disclosure Project,
and the Greenhouse Gas Protocol16 can help
utilities achieve this goal within an accepted
framework.
Along with a rigorous accounting for carbon
cost, setting a target for GHG reductions is
important. Once a target is established, utility
managers can develop long-term action
plans across various business units that will
contribute to achieving the reduction. Building
carbon reductions into business operations
frameworks will also help foster innovation
around practices for achieving targets. Many
utility companies, including American Electric
Power, Entergy, Duke Energy, Exelon, National
Grid, Consolidated Edison, Xcel Energy, PSEG,
NiSource, and Pinnacle West, have already
set absolute or intensity targets. Many of these
companies cite multiple benefits of setting
GHG reduction targets, including improved
operational efficiencies, preparedness for
emerging regulations and enhanced standing
with key stakeholders.
It is critical that utilities capably manage

carbon across their enterprise, and properly
account for carbon exposure in their business planning. Given the challenges related to
regulatory and financial uncertainties, utilities can begin to account for carbon exposure by
16. The Greenhouse Gas Protocol (GHG Protocol) is an international accounting tool for government and business
leaders to understand, quantify, and manage greenhouse gas emissions. The GHG Protocol is a decade-long
partnership between the World Resources Institute (WRI) and the World Business Council for Sustainable
Development (WBCSD). www.ghgprotocol.org.

establishing a shadow carbon price for planning purposes.
Furthermore, utilities should develop and analyze scenarios
to explore the impacts of variations in carbon regulation
and market conditions to inform decisions throughout
the enterprise, not just around generation or supply
procurement. This will allow the utility to include carbon
externalities as it conducts its future planning, as well
as develop ways to reduce its carbon exposure. Finally,
utilities should develop carbon-related risk management
competencies and fully incorporate these into the
companys enterprise risk management (ERM) approach.
In summary, to effectively manage carbon,
utilities should:
Exelons 2020 Low Carbon Roadmap

After far surpassing its initial goal of reducing GHG
emissions by 8 percent from 2001 to 2008 (and
actually achieving a 38 percent reduction), Exelon
committed to a new 2020 goal. The Illinois-based
utility now aims to reduce, offset or displace more
than 15 million metric tons of greenhouse gas
emissions per year by 2020, roughly the same
amount that the power company emitted in 2001.
Exelons three-pronged strategy for achieving
comprehensive GHG reductions:
1. R
educe or offset its carbon footprint by
greening operations
M
ake an overall corporate commitment to minimize
carbon emissions as a central guiding policy;
2. H
elp customers and communities reduce
their emissions
P
erform rigorous scenario analysis that assumes a
range of carbon costs;
3. O
ffer more low-carbon electricity in the
marketplace
Incorporate carbon prices into business and energy

resource plans;
C
omplete an internal inventory of GHGs using widely
accepted standards;
The strategy is predicated on a comprehensive

economic analysis of the GHG abatement options
available to the company.
S
et a meaningful GHG reduction target that will help
prepare the company for future regulation; and
Disclose relevant data and plans thoroughly to stakeholders.
2 Pursue All Cost-Effective Energy Efficiency

Energy Efficiency (EE) is a critical mechanism for reducing energy consumption, maintaining
system reliability and reducing GHG emissions. In addition, energy efficiency is often the
cheapest source of energy for utilities. The Institute of Electric Efficiency (IEE), created by the
Edison Electric Institute in 2008, calls EE the first fuel for the industry. IEE states that EE is
a cost-effective way to reduce carbon emissions and moderate electricity demand growth.17
A recent report backed by the U.S. Department of Energy (DOE) and U.S. Environmental
Protection Agency (EPA) indicates that EE should be a key component of any national
climate policy because it is a low-cost way to reduce GHG emissions, and consequently helps
minimize the overall economic impact of climate action.18
17. Impact of Energy Efficiency and Demand Response on Electricity Demand, Perspectives on a Realistic United
States Electric Power Generation Portfolio: 2010 to 2050, Lisa Wood, Executive Director, Institute for Electric
Efficiency, October 26, 2009.
18. Energy Efficiency as a Low-Cost Resource for Achieving Carbon Emissions Reductions, National Action Plan on
Energy Efficiency, September 2009.
10

Energy efficiency portfolios typically save electricity at a cost of about 3 cents per kWh,
which is roughly two to three times less expensive than many supply-side resources
(Figure 4).
In addition to its advantage as the lowest-cost energy resource, energy efficiency provides
numerous benefits to utilities and customers. The National Action Plan on Energy Efficiency
(NAPEE) a consensus-based
initiative involving dozens of power
Levelized Cost of Electricity
sector, regulatory, consumer and
Notes:
Assumes Federal & state incentives.
industry representatives launched
CSP assumes trough technology.
Natural gas price of $4.57/MMBTU
in 2006 by DOE and EPA points
13.5
out the following energy efficiency
benefits:
18.0
16.0
16.5
/kWh (2010$)
14.0
12.0
10.0
9.5
9.5
8.0
7.5
6.0
4.5
2.0
erg
3.5
2.5
En
6.0
6.0
4.0
cy
cs
tai
ien
c
Effi
3.0
ol
tov
Ph
nc
Co
ing
at
ntr
er
So
ss
a
iom
on
Co
u
mb
as
m
Bio
irin
sti
ow
P
lar
-F
Co
nd
Wi
La
ll
dfi
Ga
al
rm
e
oth
Ge
Modular and quick to deploy
2.0
er
ow
p
dro
Hy
ar
cle
Nu
Figure 4: Cost of EE as Compared to Other Resources

Source: Navigant Consulting, Inc. 2010
Lower energy bills, greater

customer control, and greater
customer satisfaction
al
Co
Na
al
tur
Ga
Environmental benefits from

reduced fuel consumption
(including reduced air
pollution, GHG emissions, water
consumption, and environmental
damage from fossil fuel extraction)
Economic development
Energy security
Some states have been implementing successful EE measures for years. The State Energy
Efficiency Scorecard produced by the American Council for an Energy Efficient Economy
(ACEEE) ranks states in six categories related to energy efficiency. Table 2 shows the top
10 states as ranked according to ACEEEs six categories, along with their associated electricity
savings. As shown in the table, leading states have been able to achieve EE savings of
1 percent or more of electricity sales per year.
Top Ten States Based On ACEEEs State Energy Efficiency Scorecard
2009 Rank (2008 savings*)
2008 Rank (2007 savings*)
1. California (1.3%)
2. Massachusetts (0.86%)
3. Connecticut (1.1%)
4. Oregon (0.90%)
5. New York (0.36%)
6. Vermont (1.8%)
7. Washington (0.74%)
8. Minnesota (0.68%)
9. Rhode Island (0.81%)
10. Maine (0.91%)
1. California (1.3%)
2. Oregon (0.90%)
3. Connecticut (1.1%)
4. Vermont (1.8%)
5. New York (0.36%)
6. Washington (0.74%)
7. Massachusetts (0.86%) & Minnesota (0.68%) (tie)
9. Wisconsin (0.66%)
10. New Jersey (0.30%)
Table 2: Top States in Energy Efficiency Based On ACEEE Scorecard

*Savings as a percent of electricity sales. Source: ACEEE
11

While leading states have tended to
be located on the coasts (as Table
2 indicates), EE is gaining traction
across the country. Less experienced
states are now taking ambitious
steps toward implementing largescale EE programs. Ohio and
Indiana, for example, adopted
identical energy savings targets in
2009 ramping up to 2 percent of
annual electricity sales by 2019,
ranking among the most aggressive
targets in the nation.
1.6%
$0.040
Energy Savings as a Percent of Sales (2007)
1.4%
$0.035
Average Levelized Cost of Energy Saved ($/kWh)
1.2%
$0.030
1.0%
$0.025
0.8%
$0.020
0.6%
$0.015
0.4%
$0.010
0.2%
$0.005
0.0%
$0.000
010%
1020%
2030%
3040%
4050%
Deciles based on savings as a percent of sales
Figure 5: Cost of Energy Saved and Savings

as a Percent of the Utilitys Sales
Source: EIA, Navigant Consulting analysis
But even states with long track

records on EE continue to make significant strides. For example, Massachusetts finalized
plans in January 2010 to make EE its first fuel, with the states Department of Public
Utilities calling on electric and gas utilities to invest $2.2 billion aimed at saving customers $6
billion in energy costs. The plan establishes electricity savings targets for utilities that reach
up to 2.4 percent of annual sales by 2012, amounting to 2,600 GWh of cumulative electricity
savings by that time. By 2020, the plan calls for 30 percent of the states electricity demand
to be met by EE.
Rates without
Energy Efficiency
$65
Dollars per month (2006$)
Because EE is the lowest-cost

energy resource, successful energy
efficiency programs lower customer
electricity bills. The Northwest
Power and Conservation Council,
whose ambitious EE programs save
35,000 GWh annually and in 2008
delivered consumer savings of
Dollars per MWh (2006$)
Analysis by Navigant Consulting indicates that the utility EE programs that achieve the highest
levels of energy savings also deliver EE at the lowest cost, suggesting that energy efficiency
becomes less expensive as utilities use it more widely (Figure 5). After ranking utility EE
programs in deciles based on 2007 electricity savings, Navigant Consulting looked the top five
deciles and compared how much
energy was saved with how much it
Electricity rates may go up
but customer electric bills go down.
$80
$100
cost utilities to save it. The top decile
of utilities saved energy equal to
Bills without
$90
$75
1.4 percent of their sales at an
Energy Efficiency
Rates with
Energy Efficiency
average utility19 levelized cost of
$80
$70
less than 2 cents per kWh saved.
Bills with
Energy Efficiency
$70
$60
$60
2005
2015
2020
2025
2030
2005
2015
2025
Figure 6: Energy Efficiency Increases Rates, but Decreases Bills

Source: Tom Eckman, Northwest Power and Conservation Council, BPA Utility Energy
Efficiency Summit, March 17, 2010, and Navigant Consulting analysis.
19. U
tility cost of energy saved includes the utility program management and administration costs and the incentives
provided to customers. The incentives often cover only a portion of the total cost of the measure.
12
2020
2030

roughly $1.8 billion, has demonstrated that while the cost of energy efficiency programs may
slightly increase electricity rates, the resultant reductions in energy consumption will decrease
customer electricity bills (Figure 6).20
Furthermore, studies suggest that consumer savings increase as the magnitude of
EE investment increases. Analysis conducted during the development of the Regional
Greenhouse Gas Initiative (RGGI) in the Northeastern U.S. indicated that doubling EE
spending in the region could yield average energy bill savings of 4.7 percent for industrial
customers and 12.4 percent for residential customers by 2021 relative to the reference
case.21 Again, while per-kWh rates would increase slightly, the number of kWh used by
customers would decrease as would their bills.
EE is certainly not a new concept. For decades, government and utilities have supported
EE through appliance and lighting
programs, weatherization, and
customer education. Some utilities
and states have gone further; for
example, California places EE at the
top of its loading order of energy
resources.22 As of January 2010,
22 states had legislated some sort
Standard
of energy savings goals or Energy
Voluntary Goal
Efficiency Resource Standards
Pending Standard/Goal
(EERS), and four others have a
Combined EERS/RES
pending EERS (Figure 7).23
Like any energy resource, EE is
not without challenges. Disparities
Source: ACEEE
among states in reporting program
costs and energy savings makes it
difficult to measure EE results achieved in comparable terms. Also, determining the baseline
against which results will be measured can be difficult and varies among utilities and states.
Program results are typically reported by estimating the amount of energy savings that various
types of equipment will deliver, with state commissions increasingly requiring Monitoring
and Verification (M&V) of savings.24 Effective M&V is a critical factor in increasing the
implementation of EE across the U.S.
Figure 7: States with Energy Efficiency Resource Standards

(January 2010)
20. Tom Eckman, Northwest Power and Conservation Council.

21. Energy Efficiencys Role in Limiting RGGI Leakage, Bill Prindle, ACEEE, June 15, 2006. www.rggi.org/docs/
prindle.ppt
22. Preferred resources in Californias loading order are energy efficiency, demand response, renewables, distributed
generation and clean and efficient fossil fuel generation.
23. American Council for an Energy-Efficient Economy, March 2009. http://www.aceee.org/energy/state/
policies/4pgStateEERSsummary.pdf
24. While different states have different M&V protocol requirements, the industry trend is to require use of standard
protocols developed and used in many states and regions. Procedures for monitoring and evaluating the MW/
MWh impacts of EE programs generally build on the requirement of the International Performance Measurement
and Verification Protocol (IPMVP).
13

The benefits of EE are clear, including lower
electricity cost to consumers, less consumption
of CO2 emitting fuel for generation, and less need
for physical delivery infrastructure. The problem,
however, is that the traditional utility business
model involves supporting tremendous fixed
capital costs with revenues collected by selling
kWh to customers. Even small reductions in
sales can disproportionately harm utility earnings;
analysis commissioned by the Minnesota Public
Utilities Commission illustrates that a one percent
decline in sales can reduce earnings by about
10 percent for distribution-only utilities and
7 percent for vertically-integrated utilities.25
Therefore, while utilities have offered EE programs
for a long time, most have been doing so from a
conflicted position.
Key Features of an EE Program

The EE model being pursued by Idaho Power Company
has produced promising results at a low cost. The program
combines three important features: funding, decoupling,
and performance incentives. Through its program, the utility
reduced total sales by 0.5 percent at a cost of 1.8 cents per
kWh in utility expenditures.
Key features of the program include:
A rider for EE of 1.5 percent of base revenue, producing
about $8.5 million annually;
A Fixed Cost Adjustment to offset revenue reductions
due to lost sales; and
A Performance-Based DSM Incentive to reward the
company for exceeding program goals, and penalize it
for failing to meeting those goals.
The Fixed Cost Adjustment and Performance-Based
Some utilities have indicated that, with the right

Incentive were instituted together at the beginning of 2007 as
part of a decoupling pilot program involving the Residential
policy mechanisms in place, implementing EE is a
Service and Small General Service (commercial) customer
financially safe proposition. Revenue decoupling
classes. The program has been monitored closely by the
(or simply decoupling), discussed in more
Commission staff and other parties.
detail later in this report, is one such mechanism.
Decoupling ensures that a utility recovers exactly
All of Idahos major utilities use riders to fund EE, ensuring
that program money is available to make EE investments.
its commission-approved rate of return regardless
This program takes the next step by providing the decoupling
of sales fluctuations, thereby severing the link
mechanism that removes the financial disincentive to
between sales and profits. This allows the utility
investing in EE. Finally, the program provides the utility an
to pursue large-scale EE programs without
opportunity to be rewarded for performance.
threatening profitability, and to support the suite
of public policies (including building codes and
appliance standards) required to realize energy
efficiency at scale. Californias decoupling program is a key reason why the states per capita
power consumption has remained flat since the mid-1970s while the rest of the U.S. has
seen a doubling in energy use.
By itself, decoupling does not provide utilities with adequate financial incentive to aggressively
pursue EE. Approaches to financial incentives vary, but once a policy is in place to protect
the utility from declining sales it is generally recognized as best practice to reward utilities for
performance towards an energy savings target, with the richest incentives being reserved for
exemplary performance.26
25. R
egulatory Assistance Project, Revenue Decoupling: Standards and Criteria, Report to the Minnesota Public
Utilities Commission, 30 June 2008.
26. N
ational Action Plan on Energy Efficiency, Aligning Utility Incentives with Investment in Energy Efficiency,
November 2007.
14

There are three key elements for incentivizing energy efficiency for investor owned utilities
(Figure 8):
Program cost recovery;
Lost margin recovery; and
Performance incentives.
Expense
Lost revenue adjustment

mechanism (LRAM)
Rate case rider
Program Cost
Recovery
Lost Margin
Recovery
Margin
Decoupling
Capitalize
Rate case
deferral
Performance
payment
Performance
Incentives
Shared savings
These elements can be achieved

by utilizing a number of mechanisms
including:
Tariff riders for energy
efficiency expenses;
Capitalizing or rate basing
energy efficiency investments;
Lost revenue adjustment
mechanism (LRAM);
Decoupling;
Shared savings;
ROR adder
Performance payments; and

Rate of return adders.
It is also important that customers

receive proper education about
energy efficiency programs and
Source: National Action Plan for Energy Efficiency, November 2007
their benefits. This helps the utility
achieve greater market penetration with its energy efficiency programs, and helps customers
understand potential cost savings as well as the relevancy of energy efficiency to distributed
generation investment decisions.
Figure 8: Elements for Incentivizing EE for Investor

Owned Utilities
In summary, to pursue all cost-effective energy efficiency, utilities should:

Recognize the value of energy efficiency;
Actively seek out lessons learned and best practices from other jurisdictions;
Advocate for appropriate policies that support aggressive energy efficiency;
D
evelop goals that aim for at least 1% annual electricity savings, consistent with
results achieved by leading utility programs;
Fully include energy efficiency in electric system resource planning; and
Follow rigorous and transparent M&V protocols.
15

3 Integrate Cost-Effective Renewable Energy Resources
into the Generation Mix
A confluence of factors has made the U.S. one of the strongest and most attractive renewable
energy (RE) markets in the world an important trend given the need to reduce the power
sectors carbon footprint. Figure
9 illustrates the drivers that are
Increased
Improved Cost
stimulating the U.S. renewable
Fossil Fuel Prices
Competitiveness
& Volatility
energy market.
Jobs
Increasing
Grid Prices
/ kWh (2010$)
/ kWh (2010$)
Improvement in the economics

Alternatives
Economic
of renewable energy relative to
Market
Drivers
Customer
Difficulty Adding
Demand
for RE Sector
the market price of electricity will
Conventional
Options
continue to result in significant
Environmental
Policy
Government
additions of renewable energy
Climate Change
Incentives
Concerns
to many generation portfolios.
New Pollution
Energy
Control
Security
Technologies such as wind power
Requirements
Concerns
are currently price-competitive with
natural gas-fired power in locations
Figure 9: Renewable Energy Market Drivers in the U.S.
with strong wind resources (Wind
27
Power Class 4 or better). In 2009,
wind generation represented 39% of all new generating capacity installed, regardless of
type.28 Other renewable energy technologies such as landfill gas, solar thermal, biomass
and geothermal are also at or near competitive pricing levels (Figure 10). With continued
downward movement in price
Wholesale Renewable Energy Options
Other Options
expected across most renewable
30
30
2010
2010 With Incentives
energy sectors and upward
25
25
2017
2017 No Incentives
pressures sustaining or increasing
2017 With Incentives
2017 Assumptions:
20
20
fossil generated power costs, simple
Red: $20/ton CO cost
Blue: Higher fuel prices
$3.00/MMBtu fuel
operating economics will become an
15
15
increasingly powerful driver over the
$1.50/MMBtu
10
10
net fuel cost
near term.
0
CS
PV
me
Co
al
rci
as
m
Bio
on
ind
sti
u
mb
Co
Cla
W
s4
al
rm
e
oth
Ge
ll
dfi
Ga
an
sC
ma
Bio
rin
i
o-F
ine
CC
GT
al
Co
Ste
am
b
Tur
nc
ie
ffic
yE
erg
En
(1) High insolation (2) High Insolation (e.g. Southern California) and 2010 PV installed system price of $4.15/Wpdc;
Note: All cost estimates exclude additional revenue from renewable energy certificates. (3) GTCC = $.06/kWh and Coal Steam
Turbine = $.075/kWh in year 2010 and GTCC = $.071$.085/kWh and Coal = $.089$.11/kWh in 2017 for $4.57 & $6/MMBTU
(Gas), respectively and $1 and $3/MMBTU (Coal), respectively. A $20/ton CO2 results in ~.0075 & $.02/kWh incremental cost for
GTCC and Coal, respectively.
Figure 10: Typical Levelized Cost of Electricity

for Selected Wholesale RE Resources, Developer Financed
27. Basic Principles of Wind Resource Evaluation, American Wind Energy Association,
http://www.awea.org/faq/basicwr.html
28. AWEA U.S. Wind Industry Annual Market Report, Year Ending 2009.
16
Another key driver behind the

large-scale adoption of renewable
energy has been public policy,
including incentives and Renewable
Portfolio Standards (RPS). As of
February 2010, 29 states and
Washington D.C. had RPSs, and six
states had renewable portfolio goals
(Figure 11). If met in their entirety,

RPS Targets
AZ
15% by 2025
ND
10% by 2015 goal
CA
33% by 2020
NH
23.8% by 2025
CO
30% by 2020 (IOUs), 10% munis and co-ops
NJ
22.5% by 2021
CT
23% by 2020
NM
20% (IOUs), 10% (co-ops) by 2020
DC
20% by 2020
NV
25% by 2025
DE
20% by 2019
NY
24% by 2013
HI
40% by 2030
OH
25% by 2025
IA
105 MW (2% by 1999), add'l 1000 MW goal by 2011
OR
25% (large utilities), 5%10% (small utilities) by 2025
IL
25% by 2025
PA
18% in 2020
KS
20% by 2020
RI
16% by 2020
MA1
15% by 2020 ( +1%/year after for tier 1; 3.6% tier 2)
SD
10% by 2015 goal
MD
20% by 2022
TX
5,880 MW by 2015
ME2
10% additional by 2017 class 1
UT
20% by 2025 goal
MI
10% +1,100 MW by 2015
VA
15% of 2007 sales by 2025 goal
MN
25% by 2025, (Xcel 30% by 2020)
VT
Energy growth 20052012 goal met by RE; 20% RE &

CHP by 2017
MO
15% by 2021
WA
15% by 2020
MT
15% by 2015
WI
10% by 2015
NC
12.5% of 2020 sales by 2021 (IOU), 10% of 2017

sales by 2018 (muni/co-op)
WV
25% by 2025 (RE & Alt E) goal

1. MA has enacted an additional Alternative Energy
Portfolio Standard of 5% by 2020 and an added 0.25%
of sales each following year. Eligible technologies
include CHP, gasification with CO2 capture, and flywheel
energy storage among others.
2. ME has a goal of at least 3,000 MW of installed wind
capacity by 2020.
3. Guam has enacted an RPS goal of 25% by 2035.
RPS Mandates
RPS Goals
Figure 11: Renewable Energy Market Drivers in the U.S.
Source: January 2010, Database of State Incentives for Renewable Energy (DSIRE)
Annual RE Capacity Additions
(20102015 $B)
35
Annual Investment ($B)
Annual Installations (MW)
Annual Capital Investment
(20102015 MW)
12,000
10,000
8,000
6,000
4,000
2,000
0
30
25
20
15
10
5
0
2010
2011
2012
Hydro
2013
2014
Geothermal
2015
Landfill gas
2010
2011
Biomass
2012
Solar
2013
2014
2015
Wind
Forecasts assume 1) no renewal of existing federal tax credits after their current expiration dates and
2) no new federal stimulus program is created.
Figure 12: Expected Future Growth of Renewable Energy in the U.S.

existing state targets would require

122.2 GW of renewable energy, or
330% of existing wind and solar
capacity, by 2020. Furthermore,
Congress is considering national
renewable energy standards that
would encourage development of
renewable technologies in every state
in the U.S.
The improving competitiveness of
renewable energy generation has
benefited from the challenges facing
traditional forms of generation. In
the last year, there is evidence that
developing large coal and nuclear
generation may have a negative
impact on utility credit ratings.
Recently, Moodys indicated that
ratings pressure is increasing on
utilities seeking to build nuclear
plants, and characterized nuclear
generation development as having
bet-the-farm risk.29 More than
120 proposals for new coal-fired
power plants have been withdrawn
since 2000 due to concerns about
environmental and financial risks,
while another 50 face continued
legal opposition.30 Given these
challenges, utilities can be expected
to seek alternative strategies,
including increased renewable
energy access, to meet anticipated
future demand.
Navigant Consulting expects
significant growth in the U.S. for
solar technologies and some other
renewable energy technologies over
the next few years (Figure 12). As
this figure indicates, the expiration
29. New Nuclear Generation: Ratings Pressure Increasing, Moodys Global Infrastructure Finance, June 2009
30. Lester Brown, Coal-Fired Power on the Way Out?, 24 Feb 2010. http://ipsnews.net/news.asp?idnews=50449.
17

of the current federal Production
Tax Credit (PTC) in 2013 would
have a strong negative impact on
the continued strong growth of wind
power. If the PTC is extended again
in 2013, wind growth is likely to
continue to be strong beyond 2012.
Filed February 2009

500MW in 5 years3
Filed February 2010

3MW
Filed June 2008

20MW in 2 years,
Modified to 10MW
Proposed 4Q 2008
5MW
Filed February 2009

120MW in 5 years
Filed March 2008
250MW in 5 years,
Modified to 500MW3
Utility-scale wind plants are

Filed November 2007
currently the leading source of
3.5MW in 5 years
renewable energy based on installed
Filed May 2009
Filed 1/25/10
Filed July 2008
Filed May 2010
1.5MW
80MW
77MW in 4 years
35MW Program
capacity. By the end of 2009, the
wind industry had installed over
Additional Utility Programs; 3rd party or community owned:
1. SDG&E: 55MW owned by utility
Sacramento Municipal Utility District (1MW), Portland General Electric
2. ACE: 0.5MW will be utility owned and located on utility facilities
35,000 MW cumulatively in the
(>2MW), Hawaii Electric Company (16 MW), City of Ellensburg (<1 MW),
3. PG&E and SCE 50% ownership
City of St. George (<1 MW)
U.S., approximately 10,000 MW of
which roughly 28 percent of the
Figure 13: Utility Programs for Distributed Solar
total was installed in 2009 alone.
Examples of Filings for Rate Basing
Although some utilities and grid
operators have had concerns about
how large wind generation growth could impact grid operations, to date the increasing levels
of wind generation have not posed any major grid performance issues.
2
Colorados governor recently signed a

RPS Policies
Solar carve-outs/compliance
law requiring investor-owned utilities
Revenue
Opportunity to rate-base solar assets and leverage
to source 30 percent of their electricity
existing corporate functions
Opportunity
from renewables by 2020. In California,
Federal ITC
Utilities can now use the 30% ITC through 2016
lawmakers are considering legislation
that will raise the states RPS from 20
Quick way to deploy RE, avoiding challenges
Added Resource
related to transmission, interconnection, permitting
percent by 2010 to 33 percent by 2020.
Achieving this target using large-scale
3rd party solar service providers could lead
3rd Party Threat
to utility revenue erosion
renewables would require significant new
transmission capacity, currently one of
Brand Halo
Some utilities see solar as a way to create a brand halo
the major barriers to central renewable
Potential FASB
Financial Accounting Standards Board may reclassify
Power Purchase Agreements (PPAs) as debt
Changes
energy development throughout the
U.S. The siting, permitting, and cost of
Figure 14: Key Drivers of Utility Ownership of PV
new transmission infrastructure is likely
to impede large-scale development
of remotely-located renewable energy resources. To mitigate the risk involved with new
transmission development, California is leading a number of states in examining the potential
for distributed energy resources (DERs), especially solar PV.
A growing number of utilities are pursuing large-scale installations of distributed PV. While the
configurations of these systems vary, a common characteristic is utility ownership and ratebasing of the capital investment (Figure 13).
Utilities are gaining interest in solar PV for a variety of reasons such as RPS compliance, grid
18

Illustrative Northeast Utility
Moderate solar resource & power price
22
Conse
(Conservative to Aggressive scenarios)
Aggre
ssive
18
/kWh
Solar PV Levelized Cost of Electricity
rvativ
Likely
20
Point of grid parity
16
Aggressive
14
Likely
12
Conservative
Customers Avoided Cost of Electricity
10
(Conservative to Aggressive scenarios)
8
2010
2012
2014
2016
2018
2020
PV cost/performance typical for the Northeast US; Debt 8% equity 10% (80:20), 10 yrs debt, 25 yr lifetime, 30% ITC (assumed
beyond 2016); includes state incentives; 2010 electricity costs are typical for Northeast states with EIA electricity escalation rates.
Figure 15: Levelized Cost of Electricity (LCOE) vs. Avoided Cost

of Electricity for a Typical Northeast Utility (Real terms)
Utility Ownership of PV
Earlier this year, Southern California Edison (SCE) received approval by
the California Public Utilities Commission to build and own up to 250
MW of solar PV capacity and to execute contracts for up to 250 MW for
generation from similar facilities owned and maintained by Independent
Power Producers (IPP) through a competitive solicitation process.
Motivation for the program includes:
RPS compliance without additional transmission construction;
Helps to reduce system load peaks; and
Fills a gap in the California Solar Initiative program that
targets applications less than 1 MW and an RPS that targets
multi-MW systems.
Target locations for PV installation include large commercial, institutional,
and industrial rooftops sufficient to support 12MW installations.
Up to 10 percent of the systems will be ground mounted. SCE will own
50 percent of the installed PV, and 50 percent will be customer owned.
Customer owned systems will be determined through a competitive bid
with 20 year Power Purchase Agreements.
The program is limited to 500 MW of PV at cost cap of $963 million.
IPP bids will be capped at $260/MWh. Funding for the program will
come from SCE ratepayers, including 100 percent of reasonable startup
costs. SCE can recover capital costs up to $3.85 per watt without review
by the CPUC.
enhancement, public relations and

perhaps more importantly, protection
of customer relationships and business
(Figure 14). Many states, including
California, Colorado, and New Mexico
now allow third party providers to sell
solar power directly to utility customers.
As the cost of PV gets closer to grid
parity,31 these third party providers
could win customers away with new
on-site solar installations. Then, as
retail access opens up, those same
providers may offer energy services
beyond solar, further eroding the
utilitys revenue. As shown in Figure 15,
depending on the assumptions made
for PV cost reductions and increases
in conventional electricity prices, grid
parity could occur around 2015, or
sooner depending on pricing and
incentive levels.
Although utilities are required to divest
generation and operate as delivery-only
companies in some states, value studies
have shown that utility involvement in
selecting distributed renewable energy
location and managing the resource can
significantly increase renewable powers
contribution as a grid resource. Further
supporting or accelerating this trend
could increase the rate of renewable
energy adoption, but ownership
of generation by utilities must be
addressed in the states that prohibit it.
Like energy efficiency, distributed
energy resources are becoming more
highly valued. New ratemaking and
business model modifications, including
decoupling and utility ownership of
renewables, will be necessary to ensure
31. Grid parity is the point at which the cost of electricity produced by PV is equal to or cheaper than the price of
electricity purchased from the utility.
19

effective utilization of both DER and EE.
For utilities, developing a robust risk analysis
and planning process that takes into account
EE and DER scenarios and technologies is
essential. Given the progress that distributed
energy technologies are making, and given
the above-mentioned opportunity for thirdparties in some states to cherry-pick the
most attractive utility customers those who
have high electricity costs, strong credit, and
the means to implement alternative energy
solutions some utilities are facing growing
competitive pressures leading to accelerated
customer exit and revenue erosion in a
manner that breaks from past experience.32
For some electricity customers particularly
retail and manufacturing firms where
margins are critical the ability to source
competitively-priced peak PV power and fix
that cost for up to 20 years presents a value
proposition too strong to ignore. Utilities will
need to meet or exceed the value proposition
offered by third party firms in order to
compete effectively in this space.
Energy Efficiency and Distributed Renewables

for Capacity Deferral
Successfully implementing EE and DER programs requires customer
involvement. In 2008, NSTAR, with funding from the Massachusetts
Technology Collaborative (MTC), launched the Marshfield Energy
Challenge to simultaneously implement EE, RE and demand
response programs to limit demand on the local electricity
distribution system. The program was designed to build community
awareness and local commitment to implementing clean energy
and EE.
The Marshfield Energy Challenge is a first-of-its-kind program
designed to meet growing energy demand by combining targeted
EE efforts with small renewable generation and demand response
systems. The program involves energy audits, support for reducedcost installation of solar panels, and the use of direct-load-control
thermostats to help manage the peak demand for electricity on hot
summer days. The long-term goal of the $4 million initiative is zero
electrical load growth in the town.33
In parallel with NSTARs Marshfield Energy Challenge, the MTC
awarded funding to National Grid for a Summer Load Relief Program
in Everett, East Longmeadow and Brockton, Massachusetts.
This program is also expected to help defer distribution capacity
upgrades with distributed energy resources and EE.
Utility companies that meet growing customer demand by offering PV products and services
(as well as other distributed energy resources and energy efficiency offerings) have a significant
business opportunity. They have tremendous potential to expand service offerings across an
exciting and fast growing business sector, while protecting their existing relationships with some of
the most attractive members of their customer base.
In summary, to expand renewable energy, utilities should:
A
ctively pursue development of a range of renewable energy projects to meet and/or
exceed state renewable targets;
C
onsider owning PV assets to gain experience in their implementation given the potential
near-term grid parity and possible threat of third party providers serving utility customers
solar power;
E
valuate business models being used by private competitors and other utility companies to
own distributed energy resources and other renewable assets; and
C
reate new risk hedging and grid management mechanisms to deal with variance in
customer load response, and intermittent renewable energy resources.
32. N
STAR completes 600th energy audit in Marshfield. Mon Nov 24, 2008. http://www.wickedlocal.com/marshfield/
homepage/x541355162/NSTAR-completes-600th-energy-audit-in-Marshfield
20

4 Incorporate Smart Grid Technologies for Consumer
and Environmental Benefit
Smart Grid utilization is entering the mainstream, with most
U.S. utilities involved in full-scale system implementations
or pilot programs. As part of the American Recovery and
Reinvestment Act of 2009, the U.S. Department of Energy
catalyzed this activity by committing over $4 billion of
stimulus funds for Smart Grid Investment Grants and
Smart Grid Demonstrations. Over the next several years,
the electric utility industry will deploy advanced sensors,
communications infrastructure, and control systems that
will enable changes in the way electricity is produced,
delivered and used. Key components of the Smart Grid
as it is currently being implemented include Advanced
Metering Infrastructure (AMI), Distribution Automation
(DA), synchrophasor measurement and grid visualization,
and the integration of distributed energy resources (DERs),
including renewable energy and energy storage.
PG&E and Demand Response

PG&E offers a range of demand response
programs that provide financial incentives to
customers to reduce energy consumption at times
of peak demand. The programs help enhance
reliability, reduce costs, and avoid the need to
build new power plants.
PG&Es SmartAC program sends a signal to air
conditioners during energy supply emergencies,
instructing them to use less power. PG&E aims
to enroll 400,000 residential customers by 2011,
reducing peak load by 305 MW.
Additionally, the companys PeakChoice program
provides incentives to implement specific energy
savings measures at peak times and aims to
reduce load by 36 MW.
Reducing Peak Demand and Energy Consumption

A recent informal poll of Smart Grid experts revealed that active involvement of customers
and utilities understanding of consumer electricity demand as a controllable energy
resource are seen as the most transformative changes that the Smart Grid will enable.
Enabling large-scale demand response by providing customers enhanced information about
energy use and giving them the means to control it are key themes within the DOEs
ARRA Smart Grid programs.
The Smart Grid Enables
Higher Penetration of PV
Rooftop PV Installed Cumulative Capacity

Total U.S. with Low PV System Pricing
Addressing technical challenges could

result in:
20,000
Rooftop PV Penetration
without Smart Grid
Rooftop PV with Smart Grid
16,000
better interconnection standards

and processes
more prevalent time of use
tariffs options
These changes simplify interconnection
of PV and improve its economics,
increasing the projected installed
capacity by over 60% by 2020.
MWpDC
higher net metering caps
12,000
8,000
4,000
0
2010
2015
2020
Results based on Navigant Consulting PV Market Penetration Model and Low PV System Pricing. For the Rooftop PV with Smart
Grid case Navigant Consulting assumes that because key technical barriers are addressed (voltage regulation, reverse power flow
and power fluctuations/frequency regulation), that the some of the constraints on PV are relaxed and economics are improved.
Figure 16: The Smart Grid Enables More PV on Distribution Feeders

Smart metering and AMI technology

are only part of the solution. Utilities
and regulators should develop
effective pricing programs to ensure
that customers are given the signals
they need to make good decisions
about their energy consumption.
High customer participation rates in
these programs are also important.
Importantly, effective technologies
and pricing programs can have a
significant positive impact on peak
demand, allowing utilities and grid
operators to reduce the amount
of peaking and reserve capacity
needed to maintain grid reliability.
21

Since peaking capacity is often less efficient than baseload generation, peak demand
reductions could produce significant carbon reduction and financial benefits.
Integrating Renewable Energy

The Smart Grid should be instrumental in helping to integrate increasing amounts of
renewable energy into the transmission and distribution system. A recent study by Navigant
Consulting showed that by 2020, Smart Grid functionality could help increase the penetration
of distributed PV by more than 60 percent over the reference case with a traditional grid
(Figure 16).33 The main regulatory changes modeled in the study were: increasing the
amount of PV that could be net metered; standardized interconnection processes; and
enhanced electricity tariffs to allow PV owners to receive time-based payments for system
output. Each of these changes simplified the interconnection process and improved project
economics to the point where the adoption of PV increased.
Increasing Energy and Operational Efficiency

The electric transmission and distribution system is also
an indirect source of GHG emissions. The wires and
equipment that make up this infrastructure cause electrical
losses (wasted energy) as part of their normal operation.
Utilities will be able to utilize Smart Grid technologies to
optimize transmission and distribution to minimize these
energy losses, thus improving grid efficiency.
Today, operating and maintaining the grid requires a
high degree of direct human contact. Reading meters,
throwing switches, and checking equipment all require
utility personnel to physically drive around the system. The
Smart Grid should eliminate much of this work, reducing
vehicle miles traveled and associated fuel consumption and
improving utility responsiveness and customer service.
Currently, ARRA Smart Grid programs are serving as a
key driver in the deployment of Smart Grid technology
and infrastructure. However, this funding support is a tiny
fraction of the total investment required to modernize the
grid and enable the functionality necessary to achieve
the clean energy and customer benefits discussed above.
Implementing a modern Smart Grid is expected to take
10 to 20 years of steady capital investment by utilities, a
process that business cycles, regulation and customer
adoption could hinder.
AEPs gridSMARTSM Program

In 2007 American Electric Power (AEP) launched
gridSMARTSM, a Smart Grid initiative designed to
deliver a number of customer enablement and
grid efficiency benefits. Begun as a pilot project in
South Bend, Indiana with 10,000 smart meters,
the gridSMARTSM is growing into a comprehensive
demonstration program involving 110,000
customers in central Ohio.
The $150 million project is partially funded
with $75 million from the DOEs Smart Grid
Demonstration program. The demonstration will
include smart meters, distribution automation
equipment to better manage the grid, community
energy storage devices, smart appliances and
home energy management systems, a new
cyber security center, PHEVs, and installation
of utility-activated control technologies that will
reduce demand and energy consumption without
requiring customers to take action.
AEP is pursuing other gridSMARTSM projects in
Oklahoma and Texas. The company has a goal of
installing 5 million smart meters in its service areas
by 2015.
33. The Convergence of the Smart Grid with Photovoltaics: Identifying Value and Opportunities, Navigant
Consulting, January 2009.
22

Utilities should ensure that they implement the Smart Grid in a manner that maximizes
clean energy benefits, including energy efficiency and demand management, integration of
renewable and distributed energy, and grid optimization. To do this, utilities must manage the
technical risks of implementing a complex energy and information infrastructure over many
years. They should also maintain high rates of customer participation in dynamic pricing and
energy management programs.
In summary, when incorporating Smart Grid technologies, utilities should:

S
implify the interconnection and integration of distributed renewable
energy resources;
L
everage the operational efficiencies provided by Smart Grid technology to
reduce operational costs;
P
rioritize Smart Grid investments that seek to maximize benefits from energy
efficiency, energy delivery and clean energy technologies;
P
rovide customers with information and energy management technologies that
are aligned with effective pricing programs; and
B
uild out the Smart Grid by pursuing a long-term capital improvement program
premised on delivering enhanced value to consumers.
5 Conduct Robust and Transparent Resource Planning
Legislature
Commission
Environmental
Regulators
Financial
Community
Policy Framework
Energy planning has become extremely complex. Rate impacts, environmental impacts,
water scarcity, siting and equipment and construction lead times are among of the many
issues that utilities struggle with as they develop energy infrastructure plans and try to
implement them. Dealing with these issues and the stakeholders that care about them
can cause schedule delays and
increase costs. Collectively these
Society
Customers
Stakeholders / Influencers
factors increase project risks and
Key Process Inputs
can undermine utility credit quality,
Utilities
Stakeholder Input
particularly when the projects are
Process Output
very large and/or controversial.
Integrated
Planning Process
Robust and
Transparent Plan
Robust Scenarios
t&OFSHZ4VQQMZ
t%FMJWFSZ*OGSBTUSVDUVSF
t$VTUPNFS1SPHSBNT
Utility
Utility Investments
Energy Suppliers
(Central, DER)
Figure 17: Example Planning Process Framework

Utilities should employ open and

transparent planning processes that
consider the risks, probabilities,
benefits, impacts and applications
of multiple energy resources
under various scenarios. Planning
processes should include a full
commitment by utilities to implement
all cost-effective energy efficiency
and renewable energy. Resource
planning should involve greater
23

stakeholder involvement on a wider regional level and consider the full spectrum of EE and
DER resources. Finally, utilities should update planning criteria and system design standards
to reflect current and future costs for CO2, EE, DER, equipment and permitting. Figure
17 presents an example planning process framework that could be used to ensure the
development of robust and transparent resource and system plans.
This process ensures that the
utility receives crucial input from
the community at large. It enables
the utility to reach out and educate
customers, regulators, communities,
and key influencers on issues that
have significant impact on the
utilitys planning and operations.
Clear policy frameworks allow all
parties to better understand the goals
and regulatory objectives that will
influence or constrain the planning
process. Finally, the development of
robust planning scenarios, including
assumptions about technology costs,
carbon price, performance metrics,
and risks, ensures that all parties have
a better understanding of the tradeoffs
and subtleties of different options.
In summary, utility planning

processes should:
Utilize transparent analysis
and decision frameworks;
Fairly evaluate EE and RE
in robust scenario analyses;
Facilitate input from key
stakeholders; and
Educate the public and
policy makers about complex
energy issues.
24
Engaging Stakeholders in the Planning Process

In January 2009, Arizona Public Service (APS) filed a Resource Plan
Report with the Arizona Corporation Commission laying out the companys
plan to meet 55 percent customer demand growth by 2025 with effectively
no increase in carbon emissions. Arizona had not conducted a formal
integrated resource planning process (IRP) since 1995, and APS filed its
report voluntarily.
APSs Resource Plan Report emerged from a series of informal and frank
conversations with environmental stakeholders and, later, RE developers,
merchant generators, large customers, Arizonas Energy Office and other
utilities on the subject of meeting Arizonas future energy needs. APSs
goal was not only to obtain a wide spectrum of candid feedback, but also
to inform stakeholders about real challenges the company faced. In total,
APS conducted seven half-day stakeholder meetings on topics such as
climate change, RE, resource selection and load forecasting and held
additional meetings with community leaders and city councils throughout
the state.
What began as an experiment is now viewed by APS as essential to its
planning process going forward. APS found that focused outreach and
collaboration with a small group of key stakeholders supplemented by
broader outreach and communication effectively educated stakeholders
(and the utility) about key issues and resources and built credibility and
support for APSs future plans.
According to APS, proactive resource planning provides several important
benefits to utilities:
Positions the utility as a leader on a number of issues, including
transmission, RE, and future mandatory planning;
Educates stakeholders on the current and future issues facing
the utility;
Creates a clearer picture of what stakeholders want; and
Helps build a relationship of trust between stakeholders and the utility.
III. Financial Implications
100%
80%
60%
40%
20%
0%
Utilities are grappling with several issues simultaneously, each of which will have major
financial impacts. Accounting for the cost of carbon could significantly increase resource
costs for some utilities that have
large portions of carbon-heavy
S&P Credit Ratings Distribution, Electric Utilities
generation in their resource mixes.
However, utilities are also faced with
massive reinvestment in the existing
delivery infrastructure at the same
A or higher
A
they are implementing the Smart
BBB+
Grid and its associated technologies.
BBB
All of this will require a very large,
BBB or below
diverse long- term investment
Below BBB
program that will have significant
effects on revenue requirements and
rate bases.
In the past, utilities were well known
as low risk investments, with the
Figure 18: Long-Term Decline in Credit Quality
majority having S&P credit ratings
(S&P Credit Ratings, Electric Utilities)
of A or higher. This meant that they
Sources: Wall Street Turmoil: Impacts on Electric Utilities, Richard McMahon, Jr.,
Edison Electric Institute, NARUC Winter Committee Meetings, February 17, 2009;
were positioned to attract large
and Q3 2009 Financial Update, Credit Ratings, Edison Electric Institute.
amounts of capital at very attractive
rates that allowed them to build
large power plants and transmission lines while managing the cost to customers. Today, the
average credit rating for the industry has slipped to BBB (Figure 18), increasing utilities cost
of debt and the overall cost of financing the transition to a cleaner power sector.
4/16/1992
100
80
60
40
20
9/30/2009
Over the last five years, annual capital expenditures by U.S. shareholder-owned utilities have
almost doubled to over $84 billion
Capital Expenditures ($ Billions)
Cash from Operations CapEx ($ Billions)
per year (Figure 19). At this rate,
U.S. Shareholder-Owned Electric Utilities
U.S. Shareholder-Owned Electric Utilities
these utilities could invest almost
30
$1 trillion in capital over the next
84.2
20
17.0
10 years in generation, transmission
74.1
14.0
and distribution assets. An outcome
9.6
10
59.9
of this increase in capital spending
1.9
(CapEx) has been a reduction in
48.4
0
43.0
41.1
cash flow (cash from operations
(10)
(7.5)
minus CapEx). As utilities continue
to pursue large capital investment
(20)
programs, they must be able to
(20.9)
ensure that the investments are
(30)
2003 2004 2005 2006 2007 2008
2003 2004 2005 2006 2007 2008
allowed into their rate base by
state utility commissions to support
Figure 19: CapEx and Impacts on Cash Flow
revenue requirements. Otherwise,
Source: Edison Electric Institute
the utilities will incur financing costs
25

without offsetting revenues, which
will increase overall costs and could
negatively impact credit ratings.
14
A critical challenge with rate-basing

billions of dollars of new CapEx is
that regulators and customers are
concerned about associated rate
increases. Over the past 10 years
average retail electricity rates have
increased an average of 50 percent
across all sectors (Figure 20).
Increasing electricity rates even more
to pay for clean energy and grid
modernization will be challenging,
particularly in todays down economy
with high unemployment, and utility
regulators will be concerned about
rate impacts to customers.
10
Residential
12
Commercial
Industrial
All Sectors
/kWh
1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009
Figure 20: Historical Average Retail Electricity Prices to Customers,

1995 to 2009
Source: US Energy Information Administration
The regulatory approval process for large-scale investment decisions presents a significant
risk to utilities in the long term. Pursuing approaches that are overly capital-intensive puts
upward pressure on electricity rates and increases the risk of unfavorable recovery of cost.
This, in turn, could lower a utility's credit rating and increase its cost of capital. Some financial
analysts are predicting that key credit metrics for utilities will be negatively impacted in the
long term due to cost recovery risks from downward rate pressure.34 Utilities that pursue
diversified strategies utilizing cost-effective energy efficiency and distributed energy resources
are likely to reduce capital investment risk.
Along with a resistance to increasing rates, the economic recession has resulted in significant
reductions in electricity demand across the country, particularly in the industrial sector. This
reduction translated to dramatic decreases in retail sales revenue for utilities, and forced
many utilities to make sizable cutbacks in capital budgets and operating expenses. All of this
demonstrated the potential long-term impact of declines in electricity consumption under a
scenario where utility revenues remain tied to kilowatt-hour sales.
Recent reductions of customer demand highlight the inherent conflict most utilities have with
fully embracing energy efficiency. Similar effects would be felt from widespread adoption of
customer owned or sited generation such as distributed PV, or any other resources that
would tend to lower energy sales by utilities. These clean energy resources could end up
having a significant negative impact on utility credit quality to the extent that they erode
retail electricity sales. This effect will be compounded if utilities are also forced to enhance
electricity delivery infrastructure and grid operations to manage high penetrations of
distributed energy resources.
34. M
oodys Investors Service, Annual Outlook: U.S. Electric Utilities Face Challenges Beyond Near-Term,
January 2010.
26

Rate decoupling mechanisms offer an important potential solution by allowing utilities to
cover fixed costs regardless of energy sales. Some analysts believe that decoupling can be
beneficial to utility credit quality,35 which could lower the utility cost of capital, and reduce
the upward pressure on electricity rates. Peter Darbee, President and CEO of PG&E, cited
decoupling as part of the reason that the value of PG&Es stock dropped just 10 percent
during the recent financial recession, as opposed to an industry average of closer to
50 percent.36 PG&E still earned a reasonable return, even though its unit sales dropped.
20th Century
21st Century
Business Model
Business Model
Simple, based on steadily increasing electricity

sales typically from an expanding asset base of
centralized generation and traditional delivery
infrastructure
C
omplex, integrated energy services serving
diverse and evolving customer needs with an
information-enabled infrastructure
Sources of Revenue
Sources of Revenue
Power plant capital expenditures, primarily for

coal, nuclear, natural gas plants
P
ower plant capital expenditures, primarily for
natural gas and large scale renewables plants,
upgrades to fleet, also some coal w/CCS and
nuclear
Transmission capital expenditures

Sales of generated and procured electricity
Modest energy efficiency programs in some states
T
ransmission capital expenditures
R
ecovery of fixed and variable costs for electricity
delivery under a revenue decoupling approach
A
ggressive energy efficiency programs in most
states with financial incentives for performance
E
ffectively deployed Smart Grid technology and
services, including smart meters, energy storage,
vehicle charging, etc.
U
tility-owned distributed renewables
Table 3: An Emerging Business Model for Utilities

Plug-in electric vehicles (PEVs) provide a new opportunity for utilities to capture a larger share
of the energy market from oil companies if PEVs are deployed widely. As electric vehicles
gain consumer acceptance, utilities will face both a burden and financial opportunity as
consumers demand the necessary charging infrastructure and clean energy resources.
Finally, and perhaps most importantly, the uncertainty around the cost of reducing carbon
emissions presents great risk to the power sector, particularly for those utilities that have
carbon-heavy generation fleets or that purchase power in such markets. Some good news is
that many currently measureable risks of CO2 emissions are beginning to be incorporated into
credit quality assessments by the financial community.37 Frameworks to evaluate and address
carbon risks in the financing of electric power projects have already been put in place and are
gaining traction, such as the Enhanced Environmental Due Diligence Process of The Carbon
35. When Electric Efficiency Means Lower Electric Bills, How Do Utilities Cope?, Standard & Poors, March 2009.
36. Google CEO fires at critics, defends its energy plan (03/05/2009) Colin Sullivan, E&E reporter
37. Emission Reductions Under Cap-and-Trade Proposals in the 111th Congress, 2005 2050. World Resources
Institute. June 25, 2009. http://www.wri.org/publication/usclimatetargets
27

Principles, which is being used by Bank of America, Citi, Credit Suisse, JP Morgan Chase,
Morgan Stanley and Wells Fargo.
Some analysts believe that while the economy as a whole will feel the effects of emissions
reductions, the power sector will be required to reduce its carbon emissions to a greater
extent.38 Achieving reduction targets will go beyond pure fuel-switching from carbon-heavy
to carbon-light or carbon-free resources. Integrating clean energy resources will require new
technologies and operating practices to maintain grid reliability, and this also increases cost.
Fortunately, achieving a less carbon-intensive generation mix and smarter grid will
create opportunities for utilities to generate revenue, as outlined in Table 3 above. Capital
investments in transmission lines, smart metering and distribution automation will be
added to utility rate bases. Performance incentives for EE and service quality should
improve rates of return. And new applications such as electrification of transportation
present growth opportunities.
Effective Risk Management Approaches

The changes underway in the 21st century electric power sector create a level and complexity
of risks that is perhaps unprecedented in the industrys history. Uncertainties in the industry
which give rise to the need for more intense focus on risk assessment and risk mitigation
planning include, but are not limited to:
Inherent customer demand reduction aside from energy efficiency/DSM initiatives,
placing upward pressure on rates for allocation of fixed costs;
Cost impacts of renewable energy resources, inclusive of firming requirements needed to
integrate resources into a power supply portfolio;
Carbon compliance structure and cost uncertainties;
Uncertainty of ability to extend the commercial life, or construct planned new coal-fired
power plants due to financial market views of carbon reduction mandates/structures;
Uncertainty related to limited water supplies for power plant cooling;
Uncertainty of the effect on natural gas prices from increased demand from central
generation and capacity firming for variable renewable resources;
Challenges of timely completion of major new inter-state electric transmission to deliver
renewable energy resources to load;
Uncertainty of customer reaction to energy efficiency and DSM initiatives in the near-term
and long-term customer continued behavior;
The potential of demand-side resources not performing, requiring more expensive shortterm replacement energy; and
The extent of large load customer out-migration based on future comparative utility rates
and resultant effect on demand and cost allocation.
38. S
tandard & Poors, The Potential Credit Impact Of Carbon Cap-And-Trade Legislation On U.S. Companies,
Sept. 14, 2009.
28

In addition to the cost and customer load uncertainty examples noted above, directly related
risks which need to be managed include:
Debt rating agency interpretation of these uncertainties and risks and possible effects on
cost of debt;
For regulated utilities, the potential for disallowance of costs to the extent resultant rates
are out of regional norms or levels of comfort;
Regulatory treatment for the allocation of costs among customer classes as load
characteristics change and cost-causation by customer class changes; and
Retail customer reaction to rate effects.
Risk management actions that may need to be taken to address these risks could include:
More robust analysis of possible resource mixes and associated customer reactions, along
with more transparent sharing of resource-related assumptions and decisions, to inform
regulators, governing boards, customer groups and financial markets; and
Longer-term evaluation of resource mixes and associated ranges of revenue requirements
to better enable identification and implementation of risk management measures.
29
IV. Key State Regulatory Policies

for the 21st Century Power Sector
Key regulatory policies are required to support a sustainable 21st century power sector and to
address the important issues discussed in this report. They include:
Clean Energy Policies;
Enforceable Renewable Portfolio Standards;
Revenue Decoupling;
Effective net Metering for Distributed Generation; and
Incentive Ratemaking for Utilities.
These policies are most relevant at the state level, and typically fall within the purview of state
governments and utility regulatory commissions. It is likely that the federal government will
also set policies that put a price on carbon and increase energy independence, renewable
energy and energy efficiency.
Clean Energy Policies

Achieving clean energy results requires strong leadership in government. Today, many
states have a variety of policies that deal with certain aspects of energy, but many of these
policies do not set an overall direction that aligns clean energy goals across their government
agencies, including utility regulators. Such overarching policies are essential and serve
as blueprints for how other policies should be designed, and also help to ensure that the
mechanisms of these policies are compatible across the state.
To support a sustainable power sector, states need to make a full-fledged commitment to
clean energy and the resources of which it is composed. In the near term these would include
renewable energy, energy efficiency, distributed generation, natural gas fired generation39 and
the Smart Grid. Over the longer term, large-scale deployment renewable energy technologies
can occur, as well as possible implementation of advanced nuclear and low-carbon coal
technology. As lower-carbon resources are built, provisions for the retirement and repowering
of the higher-polluting plants can be made.
California, like Massachusetts, has a state policy that places EE at the top of the priority list
compared to other energy resources. Californias principal energy agencies established its
energy loading order in 2003 as energy efficiency, demand response, renewable energy
and distributed generation. This loading order was established to develop and operate
Californias electricity system in the best long-term interest of the consumers, ratepayers and
taxpayers. A key goal of the loading order is to decrease electricity demand, and then meet
new generation needs, first with clean energy sources such as RE and distributed generation,
and second with cleaner fossil fuel generation. This energy resource loading order continues
to drive all energy policy decisions in California.
39. N
atural gas fired generation is an attractive resource for significantly reducing CO2 emissions in the near term,
while at the same time being domestically available for the foreseeable future. 84 percent of the natural gas
consumed in the US is produced domestically, with the remainder largely supplied from Canada. Domestic
supplies have surged in recent years, with recent studies indicating that, even with a 50 percent increase
in demand, natural gas would be available for 80 years. The location of natural gas supplies as an on-shore
resource accessible by load centers is also attractive from an energy security perspective. For example, Marcellus
shale gas in western Pennsylvania is close to load centers of PJM Interconnection.
30

A clear, consistent, and coordinated energy policy is important because it sets the tone
regarding the importance and commitment to clean energy. It clarifies priorities and serves
as a roadmap for stakeholders in pursuing their detailed initiatives. It can help develop
positive public attitudes toward clean energy and consequently help ensure the availability
of resources necessary to pursue clean energy objectives. A clear state energy policy is
also critical to provide utilities the regulatory and financial incentives to develop the five key
elements of a 21st century utility business model described in this report. By establishing
a firm and consistent regulatory framework, states can provide utilities with the necessary
structure to manage their carbon emissions, ramp up investments in energy efficiency,
renewable energy and distributed energy resources, work on maximizing the carbon and
consumer benefits of the Smart Grid, and develop a robust and transparent resource
planning process.
Enforceable Renewable Portfolio Standards

Another key regulatory policy in many states is a Renewable Portfolio Standard (RPS),
discussed earlier and also known as Renewable Electricity Standard (RES). These regulations
require electricity supply companies to produce a defined fraction of their electricity from
RE sources, for which they receive renewable energy certificates (RECs). RE generators can
then sell RECs (along with electricity) to utilities, who sell the electricity to consumers and use
RECs to demonstrate compliance with the RPS standards. Supporters of RPS claim that since
the RPS relies almost entirely on the private market for its implementation, it is an effective
method to drive the growth of competition, efficiency and innovation among renewable energy
generators, driving down costs and increasing adoption.
In practice, however, the presence of an RPS does not always lead to new RE installations.
For example, sporadic implementation of the federal Production Tax Credit for wind power
producers has led to sporadic investment and installations of wind projects, which has
compromised efforts to achieve state RPS goals. Furthermore, an RPS alone is often not
sufficient to stimulate the use of RE. Several states that have a RPS in place do not have
enforcement mechanisms that incentivize compliance, and some of these states have little
or no financial penalties for not meeting the RPS. In states like New Mexico and North
Carolina, utilities are allowed to pass non-compliance costs onto ratepayers. Other states,
such as New Jersey, have established appropriate non-compliance penalties that will drive
new RE installations.
Creating a mandatory RPS would incentivize compliance and provide clear market signals for
utilities. It would reinforce the notion that RE is a high priority and reward those parties that
deliver results. It would build credibility for, and demonstrate commitment to, clean energy
policy. The presence of an RPS with appropriate enforcement mechanisms in place would
incentivize utilities to work toward developing some of the key characteristics of a leading 21st
century utility.
31

Revenue Decoupling
Revenue decoupling is a key regulatory mechanism that breaks the link between a utilitys
profits and its electricity sales. It removes the inherent disincentive for utilities to encourage
reductions in the amount of electricity used by customers. Importantly, decoupling ensures
that utilities recover fixed costs during times when sales growth is declining, a trend that has
been in play since the 1990s.
One important aspect of decoupling is the periodic adjustment in rates in order to precisely
reconcile revenue collection with the utilitys commission-approved revenue requirement. This
usually focuses on the non-fuel or non-generation portion of the cost of service, and is usually
applied across the board and does not affect rate design. Decoupling is often applied on a
customer class basis, with a reassessment of the process within three to five years. Revenues
in a sound decoupling plan will tend to track what frequent rate cases would have yielded.
In the end, a utilitys net revenue will not be affected by sales decreases or increases, thus
allowing them to focus on other priorities, notably customers.
Many utilities along with advocates,
public utility commissioners
and other experts believe that
decoupling is the key enabler
that will allow utilities to embrace
large-scale EE and DER. By
April 2010, 20 states had either
implemented electric decoupling, or
had decoupling pending (Figure 21).
Adopted Electric Decoupling (11)
Pending Electric Decoupling (9)
No Decoupling (31)
Despite decouplings advantages

including its elimination of the
throughput incentive, the financial
incentive for (non-decoupled) utilities
to sell ever-increasing amounts of
power which conflicts with climate
Figure 21: Electric Decoupling in the U.S. April 2010
stabilization goals not all parties
Source: Natural Resources Defense Council
currently favor decoupling. Some
public advocates and customer groups oppose decoupling because they believe that it
transfers risk to customers, changes rates without due consideration for all the underlying cost
changes that may have occurred and reduces the incentive of utilities to operate efficiently and
contain costs.
In simple form, decoupling guarantees utilities that if they promote energy efficiency, they will be
compensated with appropriate rates that cover fixed costs and provide an adequate return on
equity. But while decoupling eliminates a key barrier, it does not guarantee cost effective energy
efficiency, nor does it provide sufficient financial incentives for utilities to embrace large-scale
EE. Consequently, decoupling works best with well-designed performance based incentives.
Management and performance incentives include performance based earnings, shared savings,
and incentive rates-of-return. It is generally recognized as best practice to reward utilities for
32

performance towards an energy savings target, with the richest incentives being reserved for
exemplary performance.40
Given decouplings positive attributes especially its effectiveness in removing utilities
inherent conflict of interest and given concerns about alternatives to decoupling, it is
reasonable to expect that decoupling will continue to gain in popularity and become the
regulatory method of choice for maintaining utilities financial health while capturing EE as the
key resource for the 21st century power sector. Utility targets and performance incentives,
combined with the right rate model, will help ensure that utilities become drivers for EE and
DER in a manner that wont harm the utilitys credit ratings or other financial metrics.
Effective Net Metering for Distributed Generation

Net metering programs serve as an important incentive for consumer investment in
renewable energy generation. Net metering enables customers to use their own generation
sources (e.g., a rooftop solar PV panel) to offset their consumption over a billing period by
allowing their electric meters to turn backwards when they generate electricity in excess of
their demand. This offset means that customers receive retail prices for excess electricity
they generate.
It is generally thought that net metering is a low-cost, easily administered method of
encouraging customer investment in renewable energy technologies. It allows customers
to bank the energy they generate using renewable sources for use at other times. This
flexibility allows customers to maximize the revenue from their production. Utilities may
also benefit from net metering because expanded customer production of electricity during
peak periods improves the system load factor and can enable utilities to avoid expensive
investment in peak generation resources.
Currently, net metering is offered in more than 35 states. However, the presence of net
metering policy does not guarantee that net metering will drive growth in distributed
generation (DG) technologies. Many states have weak net metering policies that do not
actually encourage DG adoption. Examples include:
Preventing customers from receiving credit for excess electricity
Allowing utilities to charge excessive standby charges
The Interstate Renewable Energy Council (IREC) publishes an annual report documenting
best and worst practices in net metering policies. According to IRECs rankings, leaders
include Arizona, California, Colorado, Delaware, Florida, Maryland, New Jersey, Oregon,
Pennsylvania and Utah. Leading net metering policies in Colorado, for example, supported
the development of nearly 22 MW of solar PV capacity in 2008, an 88 percent increase over
the previous year.41
40. National Action Plan on Energy Efficiency, Aligning Utility Incentives with Investment in Energy Efficiency,
November 2007.
41. Network for New Energy Choices, Freeing the Grid: Best and Worst Practices in State Net Metering Policies
and Interconnection Procedures, November 2009.
33

Incentive Ratemaking for Utilities
To achieve the conditions that will produce meaningful increases in clean energy resources
and significant reductions in GHG emissions, utilities must be actively involved in the
transformation. To ensure that this happens, utilities need to clearly understand the rules
of the game, and receive strong signals from regulators on how to best deploy resources.
A key component of successfully implementing a clean energy strategy is to reduce or
eliminate the regulatory risk associated with these programs. Utility management will be
hesitant to embrace what some might consider non-core activities if they feel they are putting
shareholders at risk. A solution could be to create targeted incentives that give premium
returns on the right investments. In such cases, policy makers:
decide what the right investment choices are (e.g., generation with low carbon emissions,
or energy efficiency);
determine the value of the externality that is derived by selecting the right investment
(e.g., the cost of a ton of CO2); and
build a portion of the value into the rate that the utility uses with its customers
(e.g., 25 percent of the value of CO2 avoided).
An important advantage to a targeted incentive is that it be crafted to reward specific choices,
and is relatively simple to implement.
34

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The 21st Century

Ceres commissioned this report from Navigant Consulting.

Copyright 2010 by Ceres

The 21st Century

The 21st Century Electric Utility

Preface by Mindy S. Lubber

The 21st Century Electric Utility

Foreword by Tom King

The 21st Century Electric Utility

The Shifting Landscape of the 21st Century Electric Power Sector

Assumed Economy-wide CO2 Reduction Target

Billion tons CO2

While each of these drivers will

2005 = 5,982 mmT CO2

2020 = 17% below 2005

2030 = 42% below 2005

83% Reduction in CO2

Figure ES-1: Illustration of 80 percent CO2 reduction by 2050

The 21st Century Electric Utility

Simple, based on steadily increasing

Complex, integrated energy

Flattening with potential decline,

Average cost of new capacity stable

Average cost of new capacity

Moderate and increasing

Reliability, Customer Service,

Reliability, Environmental Quality,

Role of the Customer

More active, equipped with the

The 21st Century Electric Utility

The 21st Century Electric Utility

The 21st Century Electric Utility

The 21st Century Electric Utility

Key Report Recommendations for U.S. Utilities

Pursue All Cost-Effective Energy Efficiency

Integrate Cost-Effective Renewable Energy

Incorporate Smart Grid Technologies for Consumer and

The 21st Century Electric Utility

Key Report Recommendations for U.S. Utilities

Conduct Robust and Transparent Resource Planning

The 21st Century Electric Utility

Climate Change: A Major Challenge

Energy Security: A Growing National Priority

The 21st Century Electric Utility

Grid Technology: Creating Greater Intelligence

Electricity Demand: Multiple Factors

5. U.S. Energy Information Administration, Annual Energy Outlook 2010

In recent years, the idea of an electric utility

The 21st Century Electric Utility

Natural Gas: An Increasingly Important Strategic Resource

Coal: Facing an Array of Challenges

Nuclear Power and Carbon Capture and Storage:

The 21st Century Electric Utility

The 21st Century Electric Utility

II. Five Key Elements of

National Grids Approach to

Truly managing the financial risk associated with carbon will

While some utilities are beginning to account for carbon

The Legislative and Regulatory Context

The 21st Century Electric Utility

II. Five Key Elements of

Million metric tons CO2e

States and regional entities are

Midwestern GHG Reduction

How allowances will be allocated, and who they will be allocated to

Links to other trading systems, such as the European Union

Incorporate carbon prices into business and energy

Modular and quick to deploy

Lower energy bills, greater

Environmental benefits from

Performance payments; and